Photo by Lynne Barre, 

Photo by PCCS 

Photo by NMFS NWR 

Final Programmatic Environmental Impact Statement 

for the Marine Mammal Health and 

Stranding Response Program 

February 2009 

Volume I: Final Programmatic Environmental Impact Statement 

Photo by ASLC 

Photo by Ingrid Overgard 

National Marine Fisheries Service 

Office of Protected Resources 

1315 East-West Highway 

Silver Spring, MD 20910 

Lead Agency: 

National Oceanic and Atmospheric Administration (NOAA) 

National Marine Fisheries Service (NMFS) 

Office of Protected Resources 

Cooperating Agency: 

U.S. Department of Agriculture (USDA) 

Animal and Plant Health Inspection Service (APHIS) 

Programmatic Environmental Impact Statement 

for the Marine Mammal Health and Stranding Response 

Program 

Final Programmatic Environmental Impact Statement 

February 2009 

Abstract 

The National Oceanic and Atmospheric Administration’s (NOAA) National Marine Fisheries Service 

(NMFS) has the authority, delegated from the Secretary of Commerce, to take stranded marine 

mammals under Section 109(h) of the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1379) 

and to establish and manage the Marine Mammal Health and Stranding Response Program 

(MMHSRP) under Title IV of the MMPA (16 U.S.C. 1421 et seq.). The MMHSRP includes: the 

National Marine Mammal Stranding Network; the Marine Mammal Unusual Mortality Event 

Program; the National Marine Mammal Tissue Bank and Quality Assurance Program; marine 

mammal health biomonitoring, research, and development; the Marine Mammal Disentanglement 

Network; the John H. Prescott Marine Mammal Rescue Assistance Grant Program; and information 

management and dissemination. This Final Programmatic Environmental Impact Statement (FPEIS) 

analyzes the potential environmental impacts of implementing the MMSHRP activities contained in 

the proposed action and alternatives. 

Responsible Official: James H. Lecky, Director, Office of Protected Resources 

For Further Information Contact: 

Office of Protected Resources 

National Marine Fisheries Service 

1315 East-West Highway 

Silver Spring, MD 20910 

(301) 713-2322 
ABBREVIATIONS AND ACRONYMS 

AAZV American Association of Zoo 

Veterinarians 

ABR Auditory Brainstem Response 

ADFG Alaska Department of Fish and 

Game 

AEP Auditory Evoked Potential 

APHIS Animal and Plant Health 

Inspection Service 

ASHPO American Samoa Historic 

Preservation Office 

AVMA American Veterinary Medical 

Association 

BLM Bureau of Land Management 

CDFG California Department of Fish 

and Game 

CEQ Council on Environmental 

Quality 

CFR Code of Federal Regulations 

CI Co-Investigator 

CIMS Chesapeake Information 

Management System 

CITES 

Convention on International 

Trade in Endangered Species of 

Wild Fauna and Flora 

CNMI Commonwealth of the Northern 

Mariana Islands 

CPR Cardio Pulmonary Resuscitation 

CSC Coastal Service Center 

DDT Dichloro-DiphenylTrichloroethane 

DEA Drug Enforcement 

Administration 

DIN Dissolved Inorganic Nitrogen 

DIP Dissolved Inorganic Phosphorus 

DOC Department of Commerce 

DOI Department of the Interior 

DPS Distinct Population Segment 

EA Environmental Assessment 

EEZ Exclusive Economic Zone 

EFH Essential Fish Habitat 

EIS Environmental Impact Statement 

EO Executive Order 

EPA Environmental Protection 

Agency 

ERM Effects Range Median 

ERL Effect Range Low 

ESA Endangered Species Act 

ESU Evolutionary Significant Unit 

FLMNH Florida Museum of Natural 

History 

FOSC Federal On-Scene Coordinator 

FR Federal Register 

GEPA Guam Environmental Protection 

Agency 

GMP Gulf of Mexico Program 

HAB Harmful Algal Bloom 

HAS Hawaii Audubon Society 

HAZWOPER Hazardous Waste Operations 

and Emergency Response 

HSWRI Hubbs-SeaWorld Research 

Institute 

IATA International Air Transport 

Association 

ICS Incident Command System 

LOA Letter of Agreement 

m Meter 

mg/L Milligrams per liter 

MMC Marine Mammal Commission 

MMHSRA Marine Mammal Health and 

Stranding Response Act 

MMHSRP Marine Mammal Health and 

Stranding Response Program 
MMPA Marine Mammal Protection Act 

MSDS Material Safety Data Sheet 

NAO NOAA Administrative Order 

NCCR National Coastal Condition 

Report II 

NEPA National Environmental Policy 

Act 

NERR National Estuarine Research 

Reserve 

NHPA National Historic Preservation 

Act 

NMFS National Marine Fisheries 

Service 

NMMTB National Marine Mammal Tissue 

Bank 

NMS National Marine Sanctuary 

NOA Notice of Availability 

NOAA National Oceanic and 

Atmospheric Administration 

NOI Notice of Intent 

NPDES National Pollutant Discharge 

Elimination System 

NPS National Park Service 

NRCS Natural Resources Conservation 

Service 

NRDC Natural Resources Defense 

Council 

NRHP National Register of Historic 

Places 

NWHICRER Northwestern Hawaiian Islands 

Coral Reef Ecosystem Reserve 

NWR National Wildlife Refuge 

OCNMS Olympic Coast National Marine 

Sanctuary 

OSHA Occupational Safety and Health 

Administration 

OSP Optimum Sustainable Population 

PAH Polycyclic Aromatic 

Hydrocarbon 

PCB Polychlorinated Biphenyls 

PCCS Provincetown Center for Coastal 

Studies 

PEIS Programmatic Environmental 

Impact Statement 

PFMC Pacific Fishery Management 

Council 

PI Principal Investigator 

PIT Passive Integrated Transponder 

POP Persistent Organic Pollutant 

POTWs Publicly Owned Treatment 

Works 

PR1 

Office of Protected Resources, 

Permits, Conservation and 

Education Division (NMFS) 

ROD Record of Decision 

SA Stranding Agreement 

SAV Submerged Aquatic Vegetation 

SHPO State Historic Preservation 

Officer 

TCP Traditional Cultural Property 

THPO Tribal Historic Preservation 

Officer 

TOC Total Organic Carbon 

UME Unusual Mortality Event 

U.S.C. United States Code 

USCG U.S. Coast Guard 

USDA U.S. Department of Agriculture 

USFS U.S. Forest Service 

USFWS U.S. Fish and Wildlife Service 

USGS U.S. Geological Survey 

VHF Very High Frequency 

VIDPNR Virgin Islands Department of 

Planning and Natural Resources 

WDFW Washington Department of Fish 

and Wildlife 

WGMMUME

Working Group on Marine 

Mammal Unusual Mortality 

Events 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

ES-1 

1 Executive Summary 

2 The National Oceanic and Atmospheric Administration’s (NOAA) National Marine Fisheries Service 

3 (NMFS) has prepared this final Programmatic Environmental Impact Statement (PEIS) pursuant to 

4 the National Environmental Policy Act (NEPA) of 1969, the Council on Environmental Quality 

5 (CEQ) Regulations for Implementing NEPA (40 Code of Federal Regulations 1500-1508), and the 

6 NOAA environmental review procedures (NOAA Administrative Order 216-6). 

7 ES.1 Proposed Actions 

8 With the passage of the Marine Mammal Protection Act (MMPA) in 1972, Congress gave jurisdiction 

9 over marine mammals in U.S. waters to the Federal government. All cetaceans and all pinnipeds, 

10 except walrus (Odobenus rosmarus), were placed under the jurisdiction of the Department of 

11 Commerce, of which NMFS is a part. The Department of the Interior, U.S. Fish and Wildlife Service 

12 was given authority over walrus, sea otters (Enhydra lutris), sirenians (manatees [Trichechus spp.] 

13 and dugongs [Dugong dugon]), and polar bears (Ursus maritimus). 

14 In 1992, the Marine Mammal Health and Stranding Response Program (MMHSRP) was formalized 

15 with the passage of Title IV, an amendment to the MMPA entitled The Marine Mammal Health and 

16 Stranding Response Act. This Act charged the Secretary of Commerce to develop a marine mammal 

17 health and stranding response program with three goals: 

18 1. Facilitate the collection and dissemination of reference data on the health of marine mammals 

19 and health trends of marine mammal populations in the wild; 

20 2. Correlate the health of marine mammals and marine mammal populations, in the wild, with 

21 available data on physical, chemical, and biological environmental parameters; and 

22 3. Coordinate effective responses to unusual mortality events by establishing a process in the 

23 Department of Commerce in accordance with Section 404. 

24 The MMHSRP developed the following four Proposed Actions to encompass the activities of the 

25 MMHSRP: 

26 1. Issuance of the Policies and Best Practices for Marine Mammal Stranding Response, 

27 Rehabilitation, and Release (Policies and Best Practices) as final guidance. 

28 2. Issuance of a new Endangered Species Act (ESA)/MMPA permit to the MMHSRP. The new 

29 permit would include current and future response activities for endangered species, 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

ES-2 

1 disentanglement activities, biomonitoring projects, and import and export of marine mammal 

2 tissue samples. The permit would be issued no later than July 1, 2009 and would expire in 

3 five years. 

4 3. Continuation of current MMHSRP operations, including response, rehabilitation, release, and 

5 research activities, with renewal and authorization of Stranding Agreements (SAs) and 

6 Scientific Research Authorizations and other NMFS activities referenced in Section 1.3.1. 

7 4. Continuation of the Prescott Grant Program. 

8 The action area for the Proposed Actions and alternatives includes all areas where MMHSRP 

9 activities may occur. The action area encompasses the coastal zone and Exclusive Economic Zone of 

10 the U.S., its territories, and possessions, and adjacent marine waters. The coastal zone includes 

11 coastal waters, adjacent shorelands, intertidal areas, salt marshes, wetlands, and beaches. The action 

12 area also includes the marine mammal rehabilitation facilities of the stranding network. 

13 ES.2 Purpose and Need 

14 The purposes of the Proposed Actions are to respond to marine mammals in distress, including those 

15 stranded, entangled, and out of habitat, and to answer research and management questions about 

16 marine mammal health. Stranded and distressed marine mammal response is conducted for many 

17 reasons including NMFS’ legislative mandate and the need to obtain data for management and 

18 scientific purposes. Marine mammals are also sentinels of ecosystem health and may provide 

19 valuable links to human health. Response to marine mammals is also conducted out of a concern for 

20 animal welfare and ocean stewardship. 

21 NMFS is charged with the national oversight and collaboration of the MMHSRP, and creating 

22 policies that will work for the majority of participants. The MMHSRP has identified several needs 

23 for effectively carrying out the mandates of Title IV: 

24 1. Operational efficiency - To operate the MMHSRP effectively and efficiently, maximizing the 

25 benefits from opportunistic events while making the best use of limited resources; 

26 2. Quality data - To collect data on marine mammal health and health trends in an organized and 

27 consistent manner to meet current and future information needs for appropriate conservation 

28 and management; and 

29 3. Safety - To implement policies to ensure that MMHSRP activities are conducted humanely 

30 and in a manner that protects the safety of volunteers and the public to the maximum extent 

31 possible. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

ES-3 

1 ES.3 Alternatives 

2 The alternatives to implement the Proposed Actions are grouped into the following six topics: SAs 

3 and response; carcass disposal; rehabilitation activities; release activities; disentanglement; and 

4 biomonitoring and research activities. A No Action Alternative, Status Quo Alternative, and 

5 Preferred Alternative are designated under each issue. The No Action Alternative for each issue is 

6 based upon NMFS not undertaking the coordination and operation of the MMHSRP. Current SAs 

7 would not be renewed and new SAs would not be issued. The Policies and Practices manual and the 

8 ESA/MMPA permit would not be issued. As current SAs expired, the current National Stranding 

9 Network would cease to exist. Once the current ESA/MMPA permit expires on June 30, 2009, the 

10 current disentanglement network would no longer function. 

11 Table ES-1 summarizes the alternatives considered in the PEIS and which of the four Proposed 

12 Actions the alternatives would impact. 

13 Table ES-1. Alternatives Considered in Detail 

Alternative Description 

Proposed 

Action(s) 

Impacted 

Stranding Agreements and Response 

Alternative A1 No Action- SA's expire, stranding response 

would end. 

Alternative A2 Status Quo- Current SAs would be renewed, 

current stranding response activities continue. 

Final SA criteria would not be issued. 

Alternative A3 SAs issued to any applicants after review, new 

SA template would not be utilized. Final SA 

criteria would not be issued. Current and future 

activities included. 

Alternative A4 (Preferred) Final SA criteria would be implemented, new 

SA template would be utilized, current and 

future activities included. 

Alternative A5 Final SA criteria would be implemented, new 

SA template would be utilized, and response to 

threatened, endangered, or rare animals would 

be required. 

1, 2, 3, 4 

Carcass Disposal 

Alternative B1 No Action- SA's expire, no carcass disposal 

would occur, carcasses would be left where 

stranded. 

Alternative B2 Status Quo- Current methods of carcass 

disposal continue. 

Alternative B3 (Preferred) Status Quo with the recommendation to 

transport chemically euthanized animal 

carcasses off-site. 

1, 3 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

ES-4 

Table ES-1. Alternatives Considered in Detail (continued) 

Alternative Description 

Proposed 

Action(s) 

Impacted 

Rehabilitation Activities 

Alternative C1 No Action- Current SAs would expire, 

stranding response would cease, and animals 

would not be rehabilitated. 

Alternative C2 Status Quo- Current rehabilitation activities 

would continue. Final Rehabilitation Facility 

Standards would not be implemented. 

Alternative C3 (Preferred) New SAs would be issued, rehabilitation 

activities continue. Final Rehabilitation 

Facility Standards would be implemented. 

Alternative C4 New SAs would be issued, rehabilitation 

activities would continue. Rehabilitation of 

threatened, endangered, and rare animals 

would be required; response to other animals 

would be optional. Final Rehabilitation 

Facility Standards would be implemented. 

1, 2, 3, 4 

Release of Rehabilitated Animals 

Alternative D1 No Action- Current SAs would expire, 

stranding response and rehabilitation would 

cease, and therefore there would be no animals 

to release. 

Alternative D2 Status Quo- Current release activities would 

continue. Adaptive changes to release 

activities would not be permitted. Final release 

criteria would not be implemented. 

Alternative D3 (Preferred) New SAs would be issued, release activities 

continue. Final release criteria would be 

implemented and would include adaptive 

management of release activities. 

1, 2, 3, 4 

Disentanglement Activities 

Alternative E1 No Action- No disentanglement network. 

Alternative E2 Status Quo- Disentanglement network would 

continue current activities, no modifications or 

new members added 

Alternative E3 (Preferred) Disentanglement network would continue 

current activities on East Coast with 

modifications to West Coast network. The 

Disentanglement Guidelines and training 

prerequisites would be implemented. 

1, 2, 3, 4 

Biomonitoring and Research Activities 

Alternative F1 No Action- Biomonitoring and research 

activities would not occur. 

Alternative F2 Status Quo- New ESA/MMPA permit would 

continue current biomonitoring and research 

activities. 

Alternative F3 (Preferred) New ESA/MMPA permit would be issued to 

include current and future biomonitoring and 

research activities. 

2, 3 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

ES-5 

1 ES.4 Environmental Impacts and Mitigation 

2 The environmental impacts of the alternatives were analyzed for the following resources: 

3 • Biological resources: protected and sensitive habitats, submerged aquatic vegetation (SAV) 

4 and macroalgae, sea turtles, marine mammals, threatened and endangered species, fish, birds, 

5 and other wildlife; 

6 • Water and sediment quality; 

7 • Human health and safety; 

8 • Cultural resources; and 

9 • Socioeconomics. 

10 Table ES-2 summarizes the impacts on these resources from each of the alternatives. While potential 

11 adverse and beneficial effects on all of the chosen resource areas could occur, effects on marine 

12 mammals and human health and safety would be considered the most important. Mitigation measures 

13 have been developed to avoid, minimize, or eliminate the potential adverse effects on the affected 

14 resources from the proposed alternatives. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

ES-6 

1 

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Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement 

ES-7 

1 Table ES-2. Summary Matrix of Impacts 

Impact Area 

Alternatives Biological Resources Water & Sediment Quality Cultural Resources Stranding Agreements & Response Alternative A1- No Action No Action- SA's expire, stranding response would end.

Moderate, adverse effects on marine mammals, as stranded animals would be removed from the population. Valuable information on marine mammal health would not be collected. No effects on protected and sensitive habitats, SAV and macroalgae, sea turtles, fish, shellfish, other invertebrates, and birds. 

No effects on water and sediment quality. No effects on cultural resources. 

Alternative A2- Status Quo Status Quo- Current SAs would be renewed, current stranding response activities continue. Final SA criteria would not be issued. 

Minor, short-term adverse effects on protected and sensitive habitats, SAV and macroalgae, sea turtles, shellfish, and birds from equipment use or leaks on beaches/nearshore waters and the presence of responders. Minor to moderate, adverse effects on marine mammals would be expected from response activities and if new SAs are not issued. 

Minor, short-term adverse effects on surrounding sand and nearshore waters could occur from equipment leaks and euthanasia solution or other environmental contaminants in tissue, blood, and other body fluids. 

Potential minor, adverse effects on submerged cultural resources or resources buried in sand from equipment and vehicle use on beaches and nearshore waters. There would not be any effects on Alaska Natives, Native American tribes, or other aboriginal people’s cultural uses of coastal resources. 

Alternative A3 SAs issued to any applicants after review, new SA template would not be utilized. Final SA criteria would not be issued. Current and future activities included.

Same effects on biological resources as Alternative A2. Some beneficial impacts could come from allowing new SA holders to be added, given that they have the proper experience with marine mammal response, as geographic coverage would increase and new rehabilitation facilities may be added. 

Same effects as Alternative A2. Same effects as Alternative A2. 

Alternative A4 (Preferred) Final SA criteria would be implemented, new SA template would be utilized, current and future activities included. 

Same effects on biological resources as Alternative A2. Beneficial impacts from use of new techniques and tools during response activities and ability to add new SA holders. Long-term beneficial effects on marine mammals would be expected to occur with the implementation of SA criteria. 

Same effects as Alternative A2. Same effects as Alternative A2. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement 

ES-8 

Table ES-2. Summary Matrix of Impacts (con

Impact Area 

Alternatives Biological Resources Water & Sediment Quality Cultural Resources Stranding Agreements & Response Alternative A5 Final SA criteria would be implemented, new SA template would be utilized, and response to threatened endangered or rare animals would be required.

Same effects from stranding response activities as Alternative A2, with two exceptions. Beneficial effect on threatened endangered or rare animals and an adverse effect on other species. Same effects from the implementation of SA criteria as Alternative A4. 

Same effects as Alternative A2. Same effects as Alternative A2. 

Carcass Disposal Alternative B1- No Action No Action- SA's expire, no carcass disposal would occur, carcasses would be left where stranded.

 Potential adverse effects could occur from leaving carcasses on the beach to naturally decompose. Animal carcasses may contain contaminants, which could negatively impact the surrounding environment. No effects on protected and sensitive habitats, SAV and macroalgae, sea turtles, fish, shellfish, other invertebrates, and birds. 

 Potential adverse effects could occur from leaving carcasses on the beach to naturally decompose. Animal carcasses may contain contaminants, which could negatively impact the surrounding water and sediment quality. 

No effects on cultural resources. 

Alternative B2- Status Quo Status Quo- Current methods of carcass disposal continue.

Minor to moderate, short- and long-term adverse effects, as animal carcasses may contain persistent environmental contaminants or euthanasia solution, which could negatively impact the surrounding environment. Other adverse effects from burial, equipment use, spills of hazardous materials or wastes from equipment or vessels. Disposal at sea might allow contaminants to re-enter the marine environment, but would provide a benefit by serving as a food sources for marine organisms. 

Minor, short-term adverse effects on water and sediment quality could occur from equipment leaks; euthanasia solution or other contaminants in tissue, blood, and other body fluids; spills of hazardous materials or wastes from vessels. Burial and equipment use may have a negligible impact 

on erosion. 

Potential minor, long-term, adverse effects on submerged cultural resources or resources buried in sand from beach burial and equipment and vehicle use on beaches and nearshore waters. There would not be any effects on Alaska Natives, Native American tribes, or other aboriginal people’s cultural uses of coastal resources. 

Alternative B3 (Preferred) Status Quo with the recommendation to transport chemically euthanized animal carcasses off-site.

Same effects as Alternative B2, with one exception. Chemically euthanized carcasses would not be buried on-site, minimizing some of the adverse effects. 

Same effects as Alternative B2. Same effects as Alternative B2. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement 

ES-9 

Table ES-2. Summary Matrix of Impacts (con

Impact Area 

Alternatives Biological Resources Water & Sediment Quality Cultural Resources Rehabilitation Activities Alternative C1- No Action No Action- Current SAs would expire, stranding response would cease, and animals would not be rehabilitated.

Moderate, long-term, adverse effects as marine mammals would not be taken into rehabilitation and most would likely die from injuries or disease. No effects on protected and sensitive habitats, SAV and macroalgae, sea turtles, fish, shellfish, other invertebrates, and birds. 

No effects on water and sediment quality. No effects on cultural resources. 

Alternative C2- Status Quo Status Quo- Current rehabilitation activities would continue. Final Rehabilitation Facility Standards would not be implemented.

Minor to major, short- and long-term, beneficial and adverse effects on marine mammals. Potential adverse effects from sampling, anesthesia, disease, euthanasia, and not implementing the Rehabilitation Facility Standards No effects on protected and sensitive habitats, SAV and macroalgae, sea turtles, fish, shellfish, other invertebrates, and birds. 

Minor adverse effects due to use of open ocean/bay net pens and temporary pools and contamination from wastes, pathogens, etc. Rehabilitation facilities would have necessary permits for wastewater discharges. 

Potential minor to major adverse effects on from the use of temporary pools and net pens, depending on where they are sited. Net pens may disturb or damage submerged cultural resources. 

Alternative C3 (Preferred) New SAs would be issued, rehabilitation activities continue. Final Rehabilitation Facility Standards would be implemented.

Same effects as Alternative C2, with one exception. Rehabilitation Facility Standards would decrease the risk of disease transmission ensure a healthy environment, maximize the success of rehabilitation, and increase the potential for release to the wild. Would reduce animal pain and suffering. 

Same effects as Alternative C2. Same effects as Alternative C2. 

Alternative C4 New SAs would be issued, rehabilitation activities would continue. Rehabilitation of threatened endangered and rare animals would be required; response to other animals would be optional. Final Rehabilitation Facility Standards would be implemented.

 Same effects as Alternative C3, with a few exceptions. Adverse effects on animals that are not rare, threatened or endangered. These animals often serve as models for other species and this would be an indirect adverse affect on rare, threatened, and endangered species. 

Same effects as Alternative C2. Same effects as Alternative C2. 

Release of Rehabilitated Animals Alternative D1- No Action No Action- Current SAs would expire, stranding response and rehabilitation would cease, and therefore there would be no animals to release.

Adverse effects as marine mammals would not be released back to the wild, which negatively impacts all species, but especially threatened or endangered species. Beneficial effect on wild populations, as there would not be the risk of introducing a diseased animal that could potentially infect other marine mammals. No effects on protected and sensitive habitats, SAV and macroalgae, sea turtles, fish, shellfish, other invertebrates, and birds. 

No effects on water and sediment quality. No effects on cultural resources. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement 

ES-10 

Table ES-2. Summary Matrix of Impacts (con

Impact Area 

Alternatives Biological Resources Water & Sediment Quality Cultural Resources Release of Rehabilitated Animals Alternative D2- Status Quo Status Quo- Current release activities would continue. Adaptive changes to release activities would not be permitted. Final release criteria would not be implemented.

Minor, short- and long-term, adverse and beneficial effects on marine mammals. 

Release activities (tagging, marking, and transport) may have adverse effects. Released animal could carry a zoonotic disease and infect wild population. Adverse effects on all biological resources from equipment use, spills of hazardous materials or wastes from equipment or vessels. 

Minor, short-term, direct adverse effects could occur from spills of hazardous materials or wastes from release vessels or leaks from equipment into sand or surrounding waters. 

Minor, long-term, adverse effects on cultural resources buried in sand from equipment and vehicle use on beaches. 

Alternative D3 (Preferred) New SAs would be issued, release activities continue. Final release criteria would be implemented and would include adaptive management of release activities.

Same effects as Alternative D2, with one exception. Release criteria would be implemented and may reduce the effects on marine mammals. 

Same effects as Alternative D2. Same effects as Alternative D2. 

Disentanglement Activities Alternative E1- No Action No Action- No disentanglement network. 

Major, long-term adverse effects on marine mammals from ending the Disentanglement Network as animals would have increased pain and suffering and would most likely die. No significant effects on protected and sensitive habitats, SAV and macroalgae, sea turtles, fish, shellfish, other invertebrates, and birds. Gear on an entangled animal may be shed and become marine debris, which could potentially harm biological resources. 

No effects on water and sediment quality. No effects on cultural resources. 

Alternative E2- Status Quo Status Quo- Disentanglement network would continue current activities, no modifications or new members added

Minor, short-term adverse effects on protected and sensitive habitats, SAV and macroalgae, sea turtles, fish, shellfish, other invertebrates, birds, and marine mammals from spills of hazardous materials or wastes from vessels. Minor to major, short- and long-term, beneficial and adverse effects on marine mammals. Disentanglement would continue; new responders could not be added. Animal adverse reactions to close approaches, physical/chemical restraint, or be injured during the process. 

Minor, short-term, adverse effects could occur from spills of hazardous materials or wastes from release vessels. 

No effects on cultural resources. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement 

ES-11 

Table ES-2. Summary Matrix of Impacts (con

Impact Area 

Alternatives Biological Resources Water & Sediment Quality Cultural Resources Disentanglement Activities Alternative E3 (Preferred) Disentanglement network would continue current activities on East Coast with modifications to West Coast network. The Disentanglement Guidelines and training prerequisites would be implemented.

Same effects as Alternative E2, except that new responders and techniques could be added and Disentanglement Guidelines/training would be in place to 

reduce adverse effects. 

Same effects as Alternative E2. No effects on cultural resources. 

Biomonitoring & Research Activities Alternative F1- No Action No Action- Biomonitoring and research activities would not occur.

Adverse effects on marine mammals as important health information would no longer be collected. No effects on protected and sensitive habitats, SAV and macroalgae, sea turtles, fish, shellfish, other invertebrates, and birds. 

No effects on water and sediment quality. No effects on cultural resources. 

Alternative F2- Status Quo Status Quo- New ESA/MMPA permit would continue current biomonitoring and research activities.

Minor, short-term adverse effects on protected and sensitive habitats, SAV and macroalgae, sea turtles, fish, shellfish, other invertebrates, birds, and marine mammals from spills of hazardous materials or wastes from vessels or leaks from equipment into sand or surrounding waters. Protected and sensitive habitats and SAV and macroalgae could be damaged by vessels/researchers. Sea turtles/birds and their nests could be disturbed/ damaged. Fish may be caught in nets or disturbed. Minor to major, short- and long-term, adverse effects on marine mammals from close approach, tagging, marking, restraint, handling, capture, transport, sampling, and other activities. Long-term beneficial effects from collection of health information. 

 Minor, short-term, direct adverse effects could occur from spills of hazardous materials or wastes from release vessels or leaks from equipment into sand or surrounding waters. 

Adverse effects would not likely occur. Potential effects on submerged cultural resources or resources buried in sand from equipment and vehicle use on beaches and vessel use in nearshore waters. 

Alternative F3 (Preferred) New ESA/MMPA permit would be issued to include current and future biomonitoring and research activities.

Same effects as Alternative F2, with other adverse effects from new research activities. The increase in research activities would have a beneficial affect on marine mammals, as more health information would be collected. 

Same effects as Alternative F2. Same effects as Alternative F2. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

i 

1 FINAL PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT

2 FOR THE MARINE MAMMAL HEALTH AND STRANDING RESPONSE PROGRAM

3 

4 TABLE OF CONTENTS

5 

6 

7 

8 EXECUTIVE SUMMARY ....................................................................................................... ES-1

9 ES.1 Proposed Actions .......................................................................................................... ES-1

10 ES.2 Purpose and Need ......................................................................................................... ES-2

11 ES.3 Alternatives................................................................................................................... ES-3

12 ES.4 Environmental Impacts and Mitigation ........................................................................ ES-5

13 1. PURPOSE AND NEED FOR THE PROPOSED ACTIONS .................................................... 1-1

14 1.1 Introduction......................................................................................................................1-1

15 1.2 Establishment and Overview of the MMHSRP ...............................................................1-1

16 1.2.1 Establishment of the MMHSRP .........................................................................1-1

17 1.2.2 Overview of the Current MMHSRP ...................................................................1-3

18 1.3 Purpose and Need for the Actions ...................................................................................1-5

19 1.3.1 Purpose for the Actions.......................................................................................1-5

20 1.3.2 Need for the Actions...........................................................................................1-8

21 1.4 Action Area....................................................................................................................1-13

22 1.5 Public Involvement Process...........................................................................................1-14

23 1.5.1 Notice of Intent .................................................................................................1-14

24 1.5.2 Notice of Availability for the Draft PEIS .........................................................1-14

25 1.5.3 Summary of Major Comments on the Draft PEIS ............................................1-14

26 1.5.4 Review of the Final PEIS..................................................................................1-15

27 1.6 Agency Cooperation and Consultation ..........................................................................1-15

28 1.7 Organization of the PEIS ...............................................................................................1-17

29 2. ALTERNATIVES ............................................................................................................. 2-1

30 2.1 Introduction......................................................................................................................2-1

31 2.1.1 Stranding Agreements and Response Activities .................................................2-1

32 2.1.2 Carcass Disposal.................................................................................................2-5

33 2.1.3 Rehabilitation Activities .....................................................................................2-7

34 2.1.4 Release of Rehabilitated Animals.......................................................................2-9

35 2.1.5 Disentanglement Network ................................................................................2-11

36 2.1.6 Biomonitoring and Research ............................................................................2-13

37 2.2 Alternatives Considered but Eliminated from Further Analysis....................................2-14

38 2.2.1 Stranding Response Alternatives ......................................................................2-14

39 2.2.2 Carcass Disposal Alternatives ..........................................................................2-15

40 2.2.3 Rehabilitation Activities Alternatives...............................................................2-16

41 2.2.4 Release of Rehabilitated Animals Alternatives ................................................2-16

42 2.2.5 Disentanglement Alternative ............................................................................2-17

43 2.2.6 Biomonitoring and Research Activities Alternatives .......................................2-17

44 3. AFFECTED ENVIRONMENT ........................................................................................... 3-1

45 3.1 Introduction......................................................................................................................3-1
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Final Programmatic Environmental Impact Statement February 2009 

ii 

1 3.2 Biological Resources .......................................................................................................3-2

2 3.2.1 Definition of the Resource..................................................................................3-2

3 3.2.2 Affected Environment.........................................................................................3-6

4 3.3 Water and Sediment Quality..........................................................................................3-37

5 3.3.1 Definition of the Resource................................................................................3-37

6 3.3.2 Affected Environment.......................................................................................3-38

7 3.4 Cultural Resources.........................................................................................................3-42

8 3.4.1 Definition of the Resource................................................................................3-42

9 3.4.2 Affected Environment.......................................................................................3-43

10 3.5 Human Health and Safety ..............................................................................................3-45

11 3.5.1 Definition of the Resource................................................................................3-45

12 3.5.2 Affected Environment.......................................................................................3-45

13 3.6 Socioeconomics .............................................................................................................3-50

14 3.6.1 Definition of the Resource................................................................................3-50

15 3.6.2 Affected Environment.......................................................................................3-50

16 4. ENVIRONMENTAL CONSEQUENCES ............................................................................. 4-1

17 4.1 Introduction......................................................................................................................4-1

18 4.2 Biological Resources .......................................................................................................4-3

19 4.2.1 Stranding Agreements and Response Alternatives .............................................4-3

20 4.2.2 Carcass Disposal Alternatives ..........................................................................4-12

21 4.2.3 Rehabilitation Activities Alternatives...............................................................4-15

22 4.2.4 Release of Rehabilitated Animals Alternatives ................................................4-20

23 4.2.5 Disentanglement Alternatives...........................................................................4-24

24 4.2.6 Biomonitoring and Research Activities Alternatives .......................................4-28

25 4.3 Water and Sediment Quality..........................................................................................4-40

26 4.3.1 Stranding Agreements and Response Alternatives ...........................................4-40

27 4.3.2 Carcass Disposal Alternatives ..........................................................................4-41

28 4.3.3 Rehabilitation Activities Alternatives...............................................................4-44

29 4.3.4 Release of Rehabilitated Animals Alternatives ................................................4-45

30 4.3.5 Disentanglement Alternatives...........................................................................4-46

31 4.3.6 Biomonitoring and Research Activities Alternatives .......................................4-47

32 4.4 Cultural Resources.........................................................................................................4-48

33 4.4.1 Stranding Agreements and Response Alternatives ...........................................4-48

34 4.4.2 Carcass Disposal Alternatives ..........................................................................4-49

35 4.4.3 Rehabilitation Activities Alternatives...............................................................4-50

36 4.4.4 Release of Rehabilitated Animals Alternatives ................................................4-50

37 4.4.5 Disentanglement Alternatives...........................................................................4-51

38 4.4.6 Biomonitoring and Research Activities Alternatives .......................................4-52

39 4.5 Human Health and Safety ..............................................................................................4-53

40 4.5.1 Stranding Agreements and Response Alternatives ...........................................4-53

41 4.5.2 Carcass Disposal Alternatives ..........................................................................4-55

42 4.5.3 Rehabilitation Activities Alternatives...............................................................4-57

43 4.5.4 Release of Rehabilitated Animals Alternatives ................................................4-59

44 4.5.5 Disentanglement Alternatives...........................................................................4-59

45 4.5.6 Biomonitoring and Research Activities Alternatives .......................................4-61

46 4.6 Socioeconomics .............................................................................................................4-62

47 4.6.1 Stranding Agreements and Response Alternatives ...........................................4-62

48 4.6.2 Carcass Disposal Alternatives ..........................................................................4-65

49 4.6.3 Rehabilitation Activities Alternatives...............................................................4-67
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Final Programmatic Environmental Impact Statement February 2009 

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1 4.6.4 Release of Rehabilitated Animals Alternatives ................................................4-68

2 4.6.5 Disentanglement Alternatives...........................................................................4-69

3 4.6.6 Biomonitoring and Research Activities Alternatives .......................................4-69

4 5. MITIGATION ................................................................................................................. 5-1

5 5.1 Introduction......................................................................................................................5-1

6 5.2 Biological Resources .......................................................................................................5-1

7 5.2.1 Stranding Agreements and Response Alternatives .............................................5-1

8 5.2.2 Carcass Disposal Alternatives ............................................................................5-3

9 5.2.3 Rehabilitation Activities Alternatives.................................................................5-4

10 5.2.4 Release of Rehabilitated Animals Alternatives ..................................................5-6

11 5.2.5 Disentanglement Alternatives.............................................................................5-8

12 5.2.6 Biomonitoring and Research Alternatives..........................................................5-9

13 5.3 Water and Sediment Quality..........................................................................................5-16

14 5.3.1 Stranding Agreements and Response Alternatives ...........................................5-16

15 5.3.2 Carcass Disposal Alternatives ..........................................................................5-16

16 5.3.3 Rehabilitation Activities Alternatives...............................................................5-17

17 5.3.4 Release of Rehabilitated Animals Alternatives ................................................5-17

18 5.3.5 Disentanglement Alternatives...........................................................................5-17

19 5.3.6 Biomonitoring and Research Alternatives........................................................5-18

20 5.4 Cultural Resources.........................................................................................................5-18

21 5.4.1 Stranding Agreements and Response Alternatives ...........................................5-18

22 5.4.2 Carcass Disposal Alternatives ..........................................................................5-18

23 5.4.3 Rehabilitation Activities Alternatives...............................................................5-19

24 5.4.4 Release of Rehabilitated Animals Alternatives ................................................5-19

25 5.4.5 Disentanglement Alternatives...........................................................................5-19

26 5.4.6 Biomonitoring and Research Alternatives........................................................5-19

27 5.5 Human Health and Safety ..............................................................................................5-19

28 5.5.1 Stranding Agreements and Response Alternatives ...........................................5-19

29 5.5.2 Carcass Disposal Alternatives ..........................................................................5-21

30 5.5.3 Rehabilitation Activities Alternatives...............................................................5-21

31 5.5.4 Release of Rehabilitated Animals Alternatives ................................................5-22

32 5.5.5 Disentanglement Alternatives...........................................................................5-23

33 5.5.6 Biomonitoring and Research Alternatives........................................................5-23

34 5.6 Socioeconomics .............................................................................................................5-24

35 5.6.1 Stranding Agreements and Response Alternatives ...........................................5-24

36 5.6.2 Carcass Disposal Alternatives ..........................................................................5-24

37 5.6.3 Rehabilitation Activities Alternatives...............................................................5-24

38 5.6.4 Release of Rehabilitated Animals Alternatives ................................................5-24

39 5.6.5 Disentanglement Alternatives...........................................................................5-24

40 5.6.6 Biomonitoring and Research Alternatives........................................................5-24

41 6. CUMULATIVE AND OTHER IMPACTS............................................................................ 6-1

42 6.1 Resource Specific Cumulative Impact Analysis..............................................................6-1

43 6.1.1 Biological Resources ..........................................................................................6-2

44 6.1.2 Water and Sediment Quality...............................................................................6-4

45 6.1.3 Cultural Resources..............................................................................................6-4

46 6.1.4 Human Health and Safety ...................................................................................6-5

47 6.1.5 Socioeconomics ..................................................................................................6-5

48 6.2 Unavoidable Adverse Impacts .........................................................................................6-6
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Final Programmatic Environmental Impact Statement February 2009 

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1 6.3 Irreversible and Irretrievable Commitment of Resources................................................6-7

2 6.4 Relationship Between Short-term Uses and Long-term Productivity..............................6-7

3 7. PREPARERS ................................................................................................................... 7-1

4 8. REFERENCES................................................................................................................. 8-1

5 9. GLOSSARY .................................................................................................................... 9-1

6 10. INDEX .......................................................................................................................... 10-1

7 

8 APPENDICES

9 A PEIS Distribution List 

10 B Agency Coordination and Consultation 

11 C Policies and Best Practices for Marine Mammal Stranding Response, Rehabilitation and 

12 Release 

13 D Scoping Report 

14 E Biological Resources Tables 

15 F National Marine Mammal Stranding Network and Disentanglement Network Members 

16 G NMFS Permit No. 932-1489-10 

17 H General Descriptions of Research Methodologies Under the ESA/MMPA Permit 

18 I Required Take Tables for the ESA/MMPA Permit Application 

19 J Carcass Disposal Information 

20 K Prescott Grant Program 

21 L Marine Mammal Oil Spill Response Guidelines 

22 M Socioeconomic Information Summary Tables 

23 N Draft PEIS Public Comments and NMFS Responses 

24 

25 FIGURES

26 Figure 3-1. Nationwide Stranding Summary 2001-2006 ..................................................................3-14

27 Figure 3-2. Pinniped Strandings Nationwide 2001-2006 ..................................................................3-15

28 Figure 3-3. Cetacean Strandings Nationwide 2001-2006..................................................................3-16

29 Figure 3-4. Northeast Region Pinniped Strandings 2001-2006.........................................................3-18

30 Figure 3-5. Northeast Region Cetacean Strandings 2001-2006 ........................................................3-18

31 Figure 3-6. Southeast Region Pinniped Strandings 2001-2006.........................................................3-22

32 Figure 3-7. Southeast Region Cetacean Strandings 2001-2006 ........................................................3-22

33 Figure 3-8. Southwest Region Pinniped Strandings 2001-2006........................................................3-26

34 Figure 3-9. Southwest Region Cetacean Strandings 2001-2006 .......................................................3-26

35 Figure 3-10. Northwest Region Pinniped Strandings 2001-2006.....................................................3-29

36 Figure 3-11. Northwest Region Cetacean Strandings 2001-2006 .....................................................3-30

37 Figure 3-12. Alaska Region Pinniped Strandings 2001-2006 ...........................................................3-32

38 Figure 3-13. Alaska Region Cetacean Strandings 2001-2006...........................................................3-33

39 Figure 3-14. Pacific Islands Region Pinniped Strandings 2001-2006...............................................3-36

40 Figure 3-15. Pacific Islands Region Cetacean Strandings 2001-2006 ..............................................3-36

41 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

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1 TABLES

2 Table ES-1. Alternatives Considered in Detail ................................................................................ ES-3

3 Table ES-2. Summary Matrix of Impacts......................................................................................... ES-7

4 Table 4-1. Alternatives Considered in Detail ......................................................................................4-2

5 Table 4-2. Summary Matrix of Impacts ............................................................................................4-71

6 Table 6-1. Reasonably Foreseeable MMHSRP Actions .....................................................................6-1
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1 1. Purpose and Need for the Proposed Actions 

2 1.1 Introduction 

3 This final Programmatic Environmental Impact Statement (PEIS) has been prepared pursuant to the 

4 National Environmental Policy Act (NEPA) of 1969, the Council on Environmental Quality’s (CEQ) 

5 Regulations for Implementing NEPA (40 Code of Federal Regulations [CFR] 1500-1508), and the 

6 National Oceanic and Atmospheric Administration (NOAA) environmental review procedures 

7 (NOAA Administrative Order [NAO] 216-6). It describes a reasonable range of alternatives and the 

8 existing environmental conditions. The final PEIS contains a detailed analysis of the environmental 

9 consequences of the alternatives. This chapter describes the Marine Mammal Health and Stranding 

10 Response Program (MMHSRP) and the underlying purpose and need for the proposed actions. 

11 1.2 Establishment and Overview of the MMHSRP 

12 1.2.1 Establishment of the MMHSRP 

13 Public response to marine mammals in distress, particularly those that are on the beach or “stranded,” 

14 has occurred in various forms for decades. Historically, private organizations were founded to 

15 respond to stranded marine mammals. Many efforts were also conducted by museums to obtain 

16 marine mammal specimens for their collections. Aquaria with marine mammals in captivity also 

17 responded and provided veterinary care to stranded and injured marine mammals, particularly 

18 cetaceans. Prior to the 1970s, response was extremely localized, relatively inconsistent, and occurred 

19 with minimal Federal involvement. Communication between different groups responding to 

20 strandings was minimal, and accounts of single strandings were not integrated into any sort of 

21 meaningful analysis or overall picture that reflected animal stranding patterns or distributions. 

22 With the passage of the Marine Mammal Protection Act (MMPA) in 1972, Congress gave jurisdiction 

23 over marine mammals in U.S. waters to the Federal government. All cetaceans and all pinnipeds, 

24 except walrus (Odobenus rosmarus), were placed under the jurisdiction of the Department of 

25 Commerce and is now specifically housed in the National Marine Fisheries Service (NMFS), NOAA. 

26 The Department of the Interior, U.S. Fish and Wildlife Service (USFWS) was given authority over 

27 walrus, sea otters (Enhydra lutris), sirenians (manatees [Trichechus spp.] and dugongs [Dugong 

28 dugon]), and polar bears (Ursus maritimus). The MMPA protected marine mammals from capture or 

29 harassment, and NMFS implementing regulations prohibited the possession of parts from carcasses 
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Final Programmatic Environmental Impact Statement February 2009 

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1 except by those specifically authorized to do so. This was a significant driving force in the 

2 development of a formal regional stranding network. 

3 The U.S. Marine Mammal Commission (MMC) sponsored a workshop in 1977 which brought 

4 scientists together to discuss marine mammal strandings. One recommendation from that workshop 

5 was to establish a framework for a national marine mammal stranding network with regional centers 

6 and a centralized data file, coordinated by NMFS. The network was formally established, and was 

7 organized, as independent volunteer organizations coordinated through each of the NMFS 

8 jurisdictional regions. 

9 Throughout the 1980s, the stranding network continued to grow across the U.S. and worldwide. 

10 Information, mostly from stranded animals, began to accumulate on marine mammal mortalities 

11 caused by human interactions, such as fisheries, and marine mammal mass mortality events. In the 

12 late 1980s, a number of mass mortality events occurred in the U.S. and abroad, gaining significant 

13 public attention. A mass die-off of humpback whales (Megaptera novaeangliae) in the Northeast U.S. 

14 was linked to saxitoxin, resulting from a harmful algal bloom (HAB). Hundreds of bottlenose 

15 dolphins (Tursiops truncatus) stranded dead in the Southeast U.S. due to Morbillivirus infection. The 

16 investigation into these events encountered significant difficulties due to the lack of baseline data on 

17 marine mammal health and NMFS and Congressional efforts began to formalize the health and 

18 stranding program. Mounting evidence from these strandings and others showed high levels of 

19 anthropogenic contaminants, such as persistent organic pollutants (POPs), raising concerns about the 

20 overall health of marine mammal populations. Interest in marine mammal health and strandings 

21 continued to increase as the public raised concerns about deteriorating ocean conditions. Based on 

22 these growing concerns Congress passed the Marine Mammal Health and Stranding Response Act 

23 (MMHSRA) in 1992. 

24 Under the MMHSRA, the MMHSRP was formalized with the passage of Title IV, an amendment to 

25 the MMPA. This Act charged the Secretary of Commerce to develop a marine mammal health and 

26 stranding response program with three goals: 

27 1. Facilitate the collection and dissemination of reference data on the health of marine mammals 

28 and health trends of marine mammal populations in the wild; 

29 2. Correlate the health of marine mammals and marine mammal populations, in the wild, with 

30 available data on physical, chemical, and biological environmental parameters; and 
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Final Programmatic Environmental Impact Statement February 2009 

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1 3. Coordinate effective responses to unusual mortality events (UMEs) by establishing a process 

2 in the Department of Commerce in accordance with Section 404 of the MMPA. 

3 In this legislation, there is specific language relative to stranding networks. First, a stranding was 

4 defined as “an event in the wild in which (A) a marine mammal is dead and is (i) on a beach or shore 

5 of the United States; or (ii) in waters under the jurisdiction of the United States (including any 

6 navigable waters); or (B) a marine mammal is alive and is (i) on a beach or shore of the United States 

7 and is unable to return to the water; (ii) on a beach or shore of the United States and, although able to 

8 return to the water, is in need of apparent medical attention; or (iii) in the waters under the jurisdiction 

9 of the United States (including any navigable waters), but is unable to return to its natural habitat 

10 under its own power or without assistance” (16 United States Code [U.S.C.] 1421h). Secondly, the 

11 Department of Commerce is authorized by Section 112(c) of the MMPA to enter into agreements 

12 with individuals or groups to “take” marine mammals in response to a stranding event. “Take” means 

13 to “harass, hunt, capture, or kill or attempt to harass, hunt, capture, or kill any marine mammal” (16 

14 U.S.C. 1362). Title IV also mandated the implementation of several other programs under the 

15 umbrella of the MMHSRP. These programs are described below. 

16 1.2.2 Overview of the Current MMHSRP 

17 Since the passage of Title IV, the MMHSRP has grown significantly. The current MMHSRP 

18 includes the following components: 

19 • National Marine Mammal Stranding Network 

20 • Marine Mammal UME Program 

21 • National Marine Mammal Tissue Bank (NMMTB) and Quality Assurance Program 

22 • Marine Mammal Health Biomonitoring, Research, and Development 

23 • Marine Mammal Disentanglement Network 

24 • John H. Prescott Marine Mammal Rescue Assistance Grant Program (a.k.a. the Prescott 

25 Grant Program) 

26 • Information Management and Dissemination. 

27 The National Marine Mammal Stranding Network consists of organizations nationwide who respond 

28 to stranded or entangled pinnipeds (except walrus) and all cetaceans within U.S. waters. These 

29 organizations are authorized to respond under the MMPA, utilizing the authority of either Section 

30 112(c) or Section 109(h). Organizations operating under Section 112(c) authority have entered into 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

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1 formal agreements with NMFS for stranding response. These agreements are known as Stranding 

2 Agreements (SAs), previously termed Letters of Agreement (LOAs). Organizations with SAs include 

3 non-profits, for-profits, institutions of higher education, museums, governmental agencies, and 

4 individuals. Section 109(h) of the MMPA allows Federal, state, and local government employees in 

5 the line of duty to take a stranded marine mammal in a humane manner (including euthanasia) if such 

6 taking is for: the protection or welfare of the mammal; the protection of public health and welfare; or 

7 the nonlethal removal of nuisance animals. Appendix F lists the current (2009) members of the 

8 NMFS National Stranding Network. The National Stranding Database was mandated under the 

9 MMPA (16 U.S.C. 1421f) to contain marine mammal health reference data and data on species that 

10 are subject to UMEs. The establishment of a data access policy was also mandated, to allow access to 

11 marine mammal tissues in the NMMTB, any analyses conducted on these tissues, and other marine 

12 mammal data in the database. Standardized datasheets to record stranding information have been 

13 developed and are revised periodically. 

14 The Working Group on Marine Mammal Unusual Mortality Events (WGMMUME), mandated under 

15 the MMPA (16 U.S.C. 1421c), is a multidisciplinary panel of experts organized by NMFS to assist in 

16 determining criteria for UMEs. A UME is defined in the MMPA as “a stranding that is unexpected; 

17 involves a significant die-off of any marine mammal population; and demands immediate response.” 

18 The WGMMUME coordinates emergency responses and investigations into causes of mortality and 

19 morbidity. The Group also evaluates the environmental factors associated with UMEs, provides 

20 training and resources (when possible), and oversees the Marine Mammal UME Fund. 

21 The development of the NMMTB at the National Institute of Standards and Technology was 

22 mandated by the MMPA (16 U.S.C. 1421f) and initiated by NMFS. Sources of tissues include: 

23 samples from UMEs; samples from marine mammals taken incidental to commercial fishing 

24 operations; samples from marine mammals taken for subsistence purposes; biopsy samples; and any 

25 other samples properly and legally collected. The MMHSRP was mandated to issue guidance “for 

26 analyzing tissue samples (by use of the most effective and advanced diagnostic technologies and tools 

27 practicable) as a means to monitor and measure overall health trends in representative species or 

28 populations of marine mammals...”(16 U.S.C. 1421f). The NMMTB provides a long-term archive 

29 for marine mammal tissue samples, so that future retrospective analyses can be conducted. The 

30 MMHSRP also coordinates and conducts field assessments of wild populations of marine mammals, 

31 particularly in areas where there is a health question or concern, such as a previous mass stranding, 

32 UME, die-off, or outbreak. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

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1 Analogous to the stranding network, response to entangled marine mammals was conducted at a local 

2 level on an ad hoc basis for several decades. NMFS Headquarters and the NMFS Northeast Region 

3 began the formalization of the Marine Mammal Disentanglement Network in 1997, when a contract 

4 was issued to the Provincetown (Massachusetts) Center for Coastal Studies (PCCS) to respond to 

5 entangled large whales along the East Coast. The Disentanglement Network is a partnership between 

6 NMFS, PCCS, the U.S. Coast Guard (USCG), state agencies, and other entities. The 

7 Disentanglement Network is responsible for monitoring and documenting whales that have become 

8 entangled in fishing gear, as well as conducting rescue operations. PCCS has established protocols 

9 for all aspects of response, including animal care and assessment; vessel and aircraft support; and 

10 media and public information. PCCS has also developed response equipment and currently trains 

11 other members of the stranding and disentanglement networks. Personnel from the Hawaiian Islands 

12 Humpback Whale National Marine Sanctuary also provide disentanglement training. Today, over 500 

13 civilian and governmental volunteers have received training as first responders for entangled whales. 

14 Appendix F lists the current members of the Disentanglement Network. 

15 The Prescott Grant Program was established under the Marine Mammal Rescue Assistance Act of 

16 2000. NMFS was authorized to disburse funds to eligible members of the National Stranding 

17 Network for: the recovery or treatment of marine mammals; the collection of data from living or dead 

18 stranded marine mammals for scientific marine mammal health research; and facility operation costs. 

19 Since 2001, Congress has annually appropriated $4.0 million to the Program, and 187 awards totaling 

20 over $16.5 million have been disbursed to stranding network members. Projects funded by the 

21 Prescott Grant Program have resulted in an increase in stranding response, data collection, and 

22 scientific analyses. Additional information on the Prescott Grant Program is presented in Section 

23 1.3.2.4. 

24 1.3 Purpose and Need for the Actions 

25 1.3.1 Purpose for the Actions 

26 The purposes of the proposed actions are to respond to marine mammals in distress, including those 

27 stranded, entangled, and out of habitat, and to answer research and management questions about 

28 marine mammal health. Stranded and distressed marine mammal response is conducted for many 

29 reasons, including NMFS’ legislative mandate and the need to obtain data for management and 

30 scientific purposes. Marine mammals are also sentinels of ecosystem health and may provide 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

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1 valuable links to human health. Response to marine mammals is also conducted out of a concern for 

2 animal welfare and ocean stewardship. Each of these reasons will be discussed below. 

3 NMFS is charged under Title IV of the MMPA with collecting, disseminating, and investigating 

4 correlates of data on marine mammal health and investigating UMEs. Due to the scope and nature of 

5 marine mammal strandings in U.S. waters, NMFS has delegated responsibility for stranding response 

6 to local persons, organizations, and institutions through MMPA Section 112(c) agreements. These 

7 groups are required to share basic information from the response with NMFS to fulfill the statutory 

8 mandates. Data collected from stranded animals may be basic (Level A), intermediate (Level B), or 

9 detailed (Level C). Level A data includes information such as location, animal disposition, and 

10 morphological data. Level B data is supplementary on-site information, such as weather and tide 

11 conditions, animal behavior prior to and during stranding, and samples collected for life history and 

12 blood studies. Level C data includes all information collected during a necropsy examination. This 

13 information is used to develop baselines for animal biology and health; recognize trends and their 

14 potential relationships to various environmental factors; and gain knowledge necessary for improved 

15 species and habitat management (Geraci and Lounsbury 2005). NMFS also conducts many research 

16 projects to assess marine mammal health on wild free-ranging animals, including remote sampling 

17 (biopsy, breath, etc.) and captures. These research projects allow the MMHSRP to utilize controlled 

18 experimental designs (i.e., number of samples, age classes, sex, location) and collect samples from 

19 off-shore species that are rarely reported stranded on beaches. 

20 NMFS has an interest in collecting data from stranded and wild animals to monitor marine mammal 

21 population status and health. Data from stranding events and health-related research projects are 

22 utilized in marine mammal stock assessment reports. Reports of interactions between fisheries and 

23 marine mammals, particularly if the interaction may have played a role in the mortality of the marine 

24 mammal, are also very important data for fishery management. 

25 Information obtained from stranded, sampled, and captured marine mammals is also important in 

26 expanding a basic biological understanding of many species. Geographic locality of strandings and 

27 rates of occurrence can reflect species distribution and abundance; seasonal patterns may also be 

28 interpreted. For some species that are cryptic and difficult to observe at sea (e.g., Kogia sp.), 

29 population distribution information from surveys may be incomplete or underestimated. Records of 

30 stranded animals may help fill in some of the gaps. By placing tracking devices on rehabilitated and 

31 captured marine mammals, movement and diving behavior can also be studied in species that have 

32 never otherwise been tagged, in addition to assessing the fate of the released animal. Recently 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

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1 rehabilitated and tracked rare marine mammal species include Risso’s dolphins (Grampus griseus) 

2 and rough-toothed dolphins (Steno bredanensis). 

3 Samples collected from stranded marine mammals are used in a variety of scientific research projects. 

4 Life history studies utilizing tissues from stranded marine mammals can determine age (growth layer 

5 groups in teeth or bones), sexual maturity (dissection of ova or testes), and reproductive history (scars 

6 in the ovaries of females documenting ovulation and pregnancy). Other studies can determine food 

7 habits (through prey remains in stomachs and digestive tracts) and the relationship between traits and 

8 other variables (age at sexual maturity, length at sexual maturity, differences in food habits with 

9 geographic range, etc.). Field studies investigating similar attributes may require years or decades of 

10 dedicated survey or remote sensing efforts, and can only be performed on certain populations of 

11 individually identifiable marine mammal species. Scientific studies of stranded marine mammals 

12 have improved the understanding of genetic diversity and relatedness, contaminants and toxins in 

13 marine mammals, marine mammal diseases, and parasites. Most of the samples used in these studies 

14 are impossible to collect from free-ranging marine mammals, particularly offshore species which can 

15 be logistically difficult to locate and study. However, the MMHSRP is involved in several health 

16 research projects, and samples collected remotely via biopsies and other methods, or collected via 

17 health assessment captures may provide basic information about populations including genetic 

18 identification of individuals or stocks, feeding behavior, disease prevalence, toxicological 

19 information, and general population health. 

20 Marine mammals are sentinels of ocean health. As top predators in the ocean ecosystem, marine 

21 mammals reflect their prey and their environment. Many environmental contaminants and biotoxins 

22 accumulate upwards in the food web, and can be detected at high levels in predators. Changes in the 

23 temporal and geographic distribution in pathogens, prey, and toxins may be detected in stranded 

24 marine mammals. These differences reflect changes in the severity, transport, concentration, and 

25 dispersion of these elements in the environment, creating a picture of environmental variability and 

26 change over space and time. 

27 The health of marine mammals has also been linked to human health, both directly and as models. 

28 By examining strandings, threats that are shared by humans who utilize the marine ecosystem may be 

29 investigated. Marine mammals serve as models to examine the effects of biotoxins and disease on a 

30 mammalian system. Directly, many of the diseases that marine mammals have are considered 

31 “zoonotic,” which means that they have the potential to spread between animals and humans. Some 

32 zoonotic diseases that have been detected in marine mammals include brucellosis, leptospirosis, West 
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Final Programmatic Environmental Impact Statement February 2009 

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1 Nile virus, Erysipelothrix rhusiopathiae, rabies, Herpes virus, and Morbillivirus. Marine mammals 

2 can directly serve as warning signals that these disease organisms are present in the marine 

3 environment, even if they have not been detected in other sampling or monitoring programs. Marine 

4 mammals also have a direct link with human health in those areas and cultures in which consumptive 

5 uses (i.e. harvest and eating) of marine mammals are practiced. In the U.S., this occurs primarily in 

6 Alaska Native communities. 

7 A final rationale for stranding response is out of a greater concern for the ocean or the environment in 

8 general. Humans perceive themselves as caretakers of ocean resources, including marine mammals. 

9 There is a desire to responsibly manage these resources for the use and enjoyment of current and 

10 future generations. Those involved in stranding response derive a sense of accomplishment from 

11 helping marine mammals return to the wild, either immediately or after rehabilitation. 

12 1.3.2 Need for the Actions 

13 NMFS is charged with the national oversight and collaboration of the MMHSRP, and creating 

14 policies that will work for the majority of participants. The MMHSRP has identified several needs 

15 for effectively carrying out the mandates of Title IV: 

16 1. Operational efficiency - To operate the MMHSRP effectively and efficiently, maximizing the 

17 benefits from opportunistic events while making the best use of limited resources; 

18 2. Quality data - To collect data on marine mammal health and health trends in an organized and 

19 consistent manner to meet current and future information needs for appropriate conservation 

20 and management; and 

21 3. Safety –To implement policies to ensure that MMHSRP activities are conducted humanely 

22 and in a manner that protects the safety of volunteers and the public to the maximum extent 

23 possible. 

24 To meet the purpose and need, the MMHSRP developed the following four proposed actions: 

25 1. Issuance of the Policies and Best Practices for Marine Mammal Stranding Response, 

26 Rehabilitation, and Release (a.k.a. Policies and Best Practices) as final guidance. 

27 2. Issuance of a new Endangered Species Act (ESA)/MMPA permit to the MMHSRP. The new 

28 permit would include current and future response activities for endangered species, 

29 disentanglement activities, biomonitoring projects, and import and export of marine mammal 

30 tissue samples. 
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1 3. Continuation of current MMHSRP operations, including response, rehabilitation, release, and 

2 research activities, with renewal and authorization of SAs and Scientific Research 

3 Authorizations and other NMFS activities referenced in Section 1.3.1. 

4 4. Continuation of the Prescott Grant Program. 

5 1.3.2.1 Policies and Best Practices Manual 

6 The Policies and Best Practices manual is a collection of protocols and guidance for stranding 

7 response, rehabilitation, and release activities. These documents, developed by NMFS (and USFWS 

8 for release activities), would be used to standardize practices of the National Stranding Network 

9 members, while allowing for regional flexibility. The manual is currently released as an interim draft 

10 and would be issued as final guidance after the NEPA analysis has been completed. Future 

11 development of these protocols and guidance may involve the issuance of regulations and subsequent 

12 NEPA analyses, but none are currently proposed. The five draft documents included in the manual 

13 are the: 

14 • Evaluation Criteria for a Marine Mammal SA (New Applicants and Renewals) (a.k.a. SA 

15 criteria) 

16 • National Template for Marine Mammal SAs 

17 • Standards for Marine Mammal Rehabilitation Facilities (a.k.a. Rehabilitation Facility 

18 Standards) 

19 • Standards for the Release of Rehabilitated Marine Mammals (a.k.a. release criteria) 

20 • Marine Mammal Disentanglement Guidelines 

21 These documents are summarized in Section 2 and their full text is located in Appendix C. 

22 1.3.2.2 ESA/MMPA Permit 

23 The NMFS Office of Protected Resources, Permits, Conservation and Education Division (PR1) 

24 issues the ESA/MMPA permit to authorize takes of marine mammals, including threatened and 

25 endangered species. The permit covers some of the MMHSRP’s activities including emergency 

26 response activities for threatened and endangered species, health assessment studies, and other 

27 research projects. 

28 The NMFS Permit No. 932-1489-10 (Appendix G), will expire on June 30, 2009 or with the issuance 

29 of the new permit, which is proposed to include new research and enhancement activities. 
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1 The current permit allows the MMHSRP Coordinator to: 

2 • Collect, receive, preserve, label, and transport marine mammal cadavers, hard parts, tissue, 

3 and fluid samples for physical, chemical, or biological analyses, import, and export; 

4 • Take stranded or distressed marine mammals and endangered or threatened species; 

5 • Salvage specimens from dead marine mammals and endangered or threatened species; 

6 • Conduct aerial surveys to locate imperiled marine mammals or survey the extent of disease 

7 outbreaks or die-offs; 

8 • Harass marine mammals on land incidental to other MMHSRP activities authorized by the 

9 permit; and 

10 • Develop and maintain cell lines from species under NMFS jurisdiction. 

11 Takes of live marine mammals include those that are stranded, entangled, disentangled, injured, 

12 trapped out of habitat, extra-limital, in peril (e.g., in vicinity of an oil spill), or are a nuisance. Takes 

13 of live animals also include those that are part of a population that is experiencing or has experienced 

14 a die-off, UME, or a repeat morbidity/mortality event. The permit does not authorize takes of 

15 USFWS marine mammal species, but fluid and tissue samples of USFWS species may be received if 

16 they were collected legally. Sources of legally obtained samples for research activities are listed in 

17 Appendix G. 

18 As the Principal Investigator (PI), the MMHSRP Coordinator may add Co-Investigators (CIs) to 

19 conduct research and enhancement activities under this permit at their discretion. Addition of CIs 

20 typically occurs following a review of the proposed activities (including protocols and statistical 

21 analyses) and curriculum vitae of the investigator. Under the current ESA/MMPA permit, animals 

22 may be taken during close approach, capture, tagging, marking, biopsy sampling, collection of 

23 sloughed skin and feces, breath sampling, blood sampling, administration of drugs, euthanasia, and 

24 incidental harassment. General descriptions of these research methodologies are in Appendix H. Live 

25 threatened and endangered species may be taken during emergency response. This includes returning 

26 the animal back to the wild; treating a distressed condition; disentangling an animal on the beach or at 

27 sea; transporting the animal for return to the wild or a treatment/rehabilitation facility; or humanely 

28 euthanizing the animal. 

29 For import and export of marine mammal specimens, the MMHSRP may be required to have import 

30 and export permits, if the species is listed on the Convention on International Trade in Endangered 

31 Species of Wild Fauna and Flora (CITES) Appendix I, II, or III. The CITES permits for import and 
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1 export are issued by the USFWS and are required to import and export samples, parts, carcasses, or 

2 live animal species (for treatment or release) listed in CITES Appendices. Species listed on CITES 

3 Appendix I require both an import permit and an export permit be issued for international shipments. 

4 Species listed on CITES Appendix II only require an export permit, unless the importing country has 

5 stricter measures than CITES. The only marine mammal listed under CITES Appendix III is the 

6 walrus. Either an export permit or a certificate of origin is required for each international shipment of 

7 walrus specimens. 

8 Under the preferred alternative (Section 2.1.6.2), the new permit would be issued on or before July 1, 

9 2009 and activities would be authorized for five years (the length allowed for a permit). 

10 ESA/MMPA permit activities beyond five years (in the event an extension is granted) would be 

11 covered under this PEIS and no further environmental review would be necessary, unless activities 

12 are beyond the scope of this document. Takes of live marine mammals under the new permit would 

13 also include animals that are: exhibiting abnormal behavior; in need of medical treatment; a potential 

14 harm or a health risk to a wild population or to human health; released from public display, 

15 rehabilitation facilities, research facilities, or capture/release projects. Live marine mammals may 

16 also be taken from rehabilitation facilities if they are neglected, abused, or have other humane issues. 

17 Samples legally obtained for research activities would be expanded to include samples from: live 

18 animals during surveillance; imported samples; confiscated animals (e.g. as part of enforcement 

19 action); or animals legally taken in other permitted research activities in the U.S. or abroad. New 

20 activities that would be listed under the new permit include, but would not be limited to, passive 

21 acoustic recording, active acoustic playbacks, and health assessment studies on cetaceans. The new 

22 permit would also allow USFWS species to be received, transferred, imported, exported, analyzed, 

23 and archived. The permit would be issued in conjunction with the USFWS Division of Management 

24 Authority in order to cover these activities. General descriptions of these research methodologies are 

25 in Appendix H. 

26 1.3.2.3 MMHSRP Operations 

27 The day-to-day operations of the MMHSRP include coordination and oversight of the National 

28 Marine Mammal Stranding Network and the Disentanglement Network. The MMHSRP authorizes 

29 response and rehabilitation activities through SAs, issued under Section 112(c) of the MMPA. SA 

30 authorizations have been delegated to the NMFS Regional Administrators. Issuance and periodic 

31 review of these SAs is undertaken by the MMHSRP through the Regional Stranding Coordinators, 

32 located in each NMFS jurisdictional region. Through SAs, NMFS authorizes persons, organizations, 
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1 or institutions to respond to reports of marine mammals that are stranded or in distress. Stranding 

2 data are collected and maintained in the National Database. The MMHSRP also coordinates UME 

3 investigations with the WGMMUME. The MMHSRP reviews the evaluation and decision to release 

4 rehabilitated animals. If rehabilitated animals are deemed non-releasable, the MMHSRP will oversee 

5 the transfer of these animals to public display or scientific research facilities. 

6 The MMHSRP authorizes marine mammal disentanglement efforts under its ESA/MMPA permit (see 

7 Section 2.1.5). The MMHSRP also funds some of the disentanglement activities through contracts. 

8 The ESA/MMPA permit also authorizes stranding response to ESA-listed marine mammal species 

9 and a variety of marine mammal research projects (see Section 2.1.6 and Appendix H). The 

10 MMHSRP issues Authorization Letters to qualified researchers to allow the use of stranded marine 

11 mammal parts in scientific research projects. The MMHSRP oversees the collection and maintenance 

12 of marine mammal tissue samples in the NMMTB. The MMHSRP also issues grants and cooperative 

13 agreements through the Prescott Grant Program to stranding network participants and researchers 

14 utilizing samples from stranded marine mammals. All activities conducted utilizing federal funds are 

15 under the authority of the SA or Authorization Letter. 

16 1.3.2.4 Prescott Grant Program 

17 The MMHSRP partially funds some of the activities of the National Marine Mammal Stranding 

18 Network through the competitive Prescott Grant Program, which disburses up to $4 million per year 

19 to stranding network members and researchers. Some of this grant money is used to fund response 

20 and rehabilitation activities (transportation, equipment, supplies, and salary) and research activities 

21 utilizing samples or data from stranded marine mammals. These activities are authorized either by 

22 the recipient’s SA, Regional Authorization letter to possess marine mammal parts from stranded 

23 animals, or separately issued ESA/MMPA scientific research permit. 

24 The awarding of competitive grants is a multi-step process which addresses compliance with NEPA 

25 and other applicable laws and regulations several times. A complete application must contain enough 

26 information on the potential environmental impacts of the project for NOAA to make a NEPA 

27 compliance determination. These applications are evaluated through technical peer-review and 

28 internal NMFS merit review panels, who take into consideration the environmental information that 

29 was provided. After the funding decision has been made regarding which projects have been 

30 selected, the Prescott program will assess the activities contained within each proposal to ensure that 

31 they have been addressed in this PEIS. These activities may include stranding response, 
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1 rehabilitation, release, and scientific research activities that are authorized under the MMHSRP’s 

2 ESA/MMPA permit. If the project falls entirely within the scope of the PEIS, no further 

3 environmental review will be conducted. If projects are selected for funding that include activities 

4 that are not assessed in this document (e.g., facility construction or renovation), a separate 

5 environmental analysis will be prepared for that award. In addition, each award may have Special 

6 Award Conditions imposed upon it with respect to environmental compliance, if necessary. 

7 A list of all projects previously funded by Prescott Grant funds, with recipient and title, is given in 

8 Appendix K. This grant program is subject to annual Congressional appropriation, which may be 

9 reduced or eliminated in any fiscal year, and recipients should consider Prescott Grant funds as 

10 supplemental to their operating budgets. 

11 1.4 Action Area 

12 The action area for the alternatives includes all areas where MMHSRP activities may occur. The 

13 action area encompasses the coastal waters and Exclusive Economic Zone (EEZ) of the U.S., its 

14 territories, and possessions, and adjacent marine waters. The coastal zone includes coastal waters, 

15 adjacent shorelands, intertidal areas, salt marshes, wetlands, and beaches. The action area also 

16 includes the marine mammal rehabilitation facilities of the stranding network (described in Section 

17 2.1.3). In Section 3.2, Biological Resources, the discussion on marine mammals has been divided 

18 according to the six NMFS regions. This has been done to address the differences in marine mammal 

19 species and strandings within each region. The states and territories included in the NMFS Northeast, 

20 Southeast, Southwest, Northwest, Alaska, and Pacific Islands regions are listed in Table 1-1. 

21 Table 1-1. Description of NMFS Regions 

NMFS Regions States/Territories 

Northeast ME, NH, MA, RI, CT, NY, NJ, PA, DE, MD, VA 

Southeast NC, SC, GA, FL, AL, MS, LA, TX, PR, VI 

Southwest CA 

Northwest OR, WA 

Alaska AK 

Pacific Islands HI, Guam, American Samoa, Commonwealth of the 

Northern Mariana Islands 

22 
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1 1.5 Public Involvement Process 

2 Public involvement is an integral part of the NEPA process. This section describes the public 

3 involvement activities conducted in connection with the draft and final versions of this PEIS. 

4 1.5.1 Notice of Intent 

5 The Notice of Intent (NOI) was published in the Federal Register (FR) on December 28, 2005 (70 FR 

6 76777-76780). The NOI announced NMFS’ decision to prepare a PEIS and conduct public scoping 

7 meetings. Scoping meetings were held in January and February of 2006 in each NMFS region. 

8 Comments on the scope of the PEIS and the Policies and Best Practices were received. The scoping 

9 process and a summary of public comments received can be found in the Scoping Report (Appendix 

10 D). Scoping comments were fully considered in the development of the draft PEIS. 

11 1.5.2 Notice of Availability for the Draft PEIS 

12 NMFS published the Notice of Availability (NOA) for the Draft PEIS on March 16, 2007 (72 FR 

13 12610). NMFS held five public hearings (in San Francisco, CA; Seattle, WA; Boston, MA; St. 

14 Petersburg, FL; and Silver Spring, MD) to solicit and receive comments. NMFS advertised these 

15 meetings via a notice in the FR. Interested parties could also send written comments to mailing and 

16 e-mail addressed printed on the title page of the draft PEIS and in the NOA. 

17 1.5.3 Summary of Major Comments on the Draft PEIS 

18 NMFS originally provided 45 days (from March 16 to April 30, 2007) for interested parties to 

19 comment on the draft PEIS. This review period was subsequently extended by 30 days to May 30, 

20 2007 (72 FR 21005). NMFS received 30 comments on the Draft PEIS, submitted by agencies, 

21 organizations, and members of the public. These comments are available online at 

22 www.nmfs.noaa.gov/pr/health/eis.htm. A complete table of these comments with NMFS’ responses is 

23 provided in Appendix N. A summary follows: 

24 • Comments on the Alternatives. Few comments were received on the alternatives. Those 

25 that were received supported the six preferred alternatives: Alternatives A4, B3, C3, D3, E3, 

26 and F3. 

27 • Comments on the Release of Rehabilitated Ice Seals. Several comments expressed 

28 opposition to the release of rehabilitated ice seals into arctic and sub-arctic waters, due to the 

29 perceived risk to wild populations of pinnipeds and potential human health impacts. 
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1 • Comments on the Policies and Best Practices. The majority of comments received on the 

2 Policies and Best Practices were in regards to the Rehabilitation Facility Standards, with 

3 suggestions for altering the minimum standards. Comments on the SA Template, the SA 

4 criteria, the release criteria, and the Marine Mammal Disentanglement Guidelines were also 

5 received. 

6 • Comments on Appendix H- Research Methodologies under the ESA/MMPA Permit. 

7 Most of the comments were suggestions for changes or additions to the research 

8 methodologies described in Appendix H. 

9 1.5.4 Review of the Final PEIS 

10 An NOA for the Final PEIS will be published in the FR. The public may comment on the document 

11 for 30 days after the NOA is published. After that time, a Record of Decision (ROD) will be 

12 prepared, detailing NMFS’ decision regarding the MMHSRP and the alternatives. 

13 1.6 Agency Cooperation and Consultation 

14 NMFS invited the MMC, USFWS, U.S. Geological Survey (USGS), and the U.S. Department of 

15 Agriculture’s (USDA) Animal and Plant Health Inspection Service (APHIS) to be cooperating 

16 agencies in the PEIS process. The USFWS and USGS declined to be cooperating agencies. The 

17 USFWS and the MMC provided comments on the Draft PEIS during the public comment period. 

18 APHIS is a cooperating agency for this PEIS. Cooperating agency responsibilities are outlined in 40 

19 CFR 1501.6. At a minimum, a cooperating agency would provide reviews of preliminary documents. 

20 Cooperating agency correspondence is included in Appendix B. 

21 Section 7 of the ESA requires that all Federal agencies consult with NMFS or USFWS, as applicable, 

22 before initiating any action that may affect a listed species. The NMFS MMSHRP initiated 

23 consultation with the NMFS Office of Protected Resources, Endangered Species Division. The draft 

24 final Biological Opinion (February 2009) concluded that the MMHSRP is not likely to jeopardize the 

25 continued existence of Guadalupe fur seal (Arctocephalus townsendi), Steller sea lion (Eumetopias 

26 jubatus) (western and eastern populations), Hawaiian monk seal (Monachus schauinslandi), blue 

27 whale (Balaenoptera musculus), bowhead whale (Balaena mysticetus), fin whale (Balaenoptera 

28 physalus), humpback whale (Megaptera novaeangliae), killer whale (Orca Orcinus) (southern 

29 resident population), North Atlantic right whale (Eubalaena glacialis), North Pacific right whale 

30 (Eubalaena japonica), sei whale (Balaenoptera borealis), and sperm whale (Physeter 

31 macrocephalus). The proposed actions are not expected to incidentally take threatened or endangered 
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1 species. Prior to proceeding with the actions proposed in this PEIS, the Biological Opinion would be 

2 completed and considered by NMFS before issuing a ROD for these actions. NMFS would abide by 

3 any reasonable and prudent measures or terms and conditions that may be required under the 

4 Biological Opinion and would sum up these requirements as part of the consideration for any ROD 

5 taken on the proposed actions analyzed in this PEIS. 

6 NMFS did not initiate formal consultation with the USFWS. Consultation for the MMHSRP actions 

7 will be conducted by regional USFWS offices. A consultation plan will be provided to NMFS and 

8 will include USFWS regional points of contact and procedures for when a consultation is required for 

9 these actions. Prior to proceeding with the actions proposed in this PEIS, the consultation plan would 

10 be completed and considered by NMFS before issuing a ROD for these actions. NMFS would abide 

11 by any reasonable and prudent measures or terms and conditions that may be required under the 

12 consultation plan and would include these in the ROD. 

13 Consultation with NMFS is also required if a proposed action permitted, funded, or undertaken by a 

14 Federal agency could adversely affect Essential Fish Habitat (EFH). The MMHSRP has consulted 

15 with the NMFS Office of Habitat Conservation regarding EFH. The Office of Habitat Conservation 

16 concurred with the determination that the MMHSRP’s activities would not adversely affect EFH. 

17 The Coastal Zone Management Act requires Federal agency activities to be consistent, to the 

18 maximum extent practicable, with states’ federally approved coastal management programs. NMFS 

19 has determined that the alternatives are consistent with the coastal management programs in the 

20 affected area. NMFS sent consistency determinations to the appropriate state coastal program 

21 administrators regarding its conclusion. NMFS received concurrence on its determinations from the 

22 following states: New Hampshire, Rhode Island, Connecticut, New York, Pennsylvania, Delaware, 

23 Virginia, North Carolina, South Carolina, Georgia, Florida, Alabama, Mississippi, Louisiana, and 

24 Hawaii. Concurrence was assumed for the following coastal management programs that did not 

25 provide a response to NMFS: Alaska, Washington, Oregon, California, Maine, Massachusetts, 

26 Maryland, New Jersey, Texas, and the Commonwealth of the Northern Mariana Islands (CNMI). 

27 Correspondence regarding coastal zone management consultation is included in Appendix B. 

28 NMFS received comments from Connecticut, Florida, and Puerto Rico State Historic Preservation 

29 Officers (SHPO). All three of the SHPOs concurred with the findings in the PEIS regarding impacts 

30 to cultural resources from MMHSRP activities. 
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1 As stated previously, this PEIS will serve as the NEPA analyses for the MMHSRP’s ESA/MMPA 

2 permit application. The final permit application was submitted to NMFS PR1 for review in 

3 December 2007. NMFS PR1 distributed the application to other NMFS scientists, the MMC, NMFS 

4 Office of Law Enforcement, and other appropriate Federal agencies. NMFS PR1 published a Notice 

5 of Receipt in the FR on March 17, 2008, which initiated a mandatory 30-day public comment period. 

6 NMFS PR1 will address any comments received on the application. NMFS PR1 will also comment 

7 on the PEIS to address any concerns relating to permit activities. Before issuance of the permit, 

8 NMFS PR1 will formally accept the Final PEIS, including the NMFS Biological Opinion, as the 

9 NEPA analysis for the permit application. A Notice of Issuance of the permit will then be published 

10 in the FR. 

11 1.7 Organization of the PEIS 

12 The principal sections of this PEIS are as follows: 

13 Section 1: Purpose of and Need for the Proposed Actions. This section briefly discusses the 

14 MMHSRP, describes the proposed actions, defines the project scope, explains the public involvement 

15 process, and identifies the organization of the document. 

16 Section 2: Alternatives. This section describes the alternatives and alternatives considered but 

17 eliminated from further consideration. 

18 Section 3: Affected Environment. This section describes the existing environmental conditions of 

19 select resources in the area in which the alternatives would occur. 

20 Section 4: Environmental Consequences. Using information from Section 3, this section identifies 

21 the potential environmental impacts on each resource area under the alternatives. Direct and indirect 

22 impacts that may result from the alternatives are identified on a broad scale as is appropriate for a 

23 PEIS. 

24 Section 5: Mitigation. This section identifies mitigation measures developed to address the potential 

25 environmental impacts identified in Section 4. 

26 Section 6: Cumulative and Other Impacts. This section discusses the potential cumulative impacts 

27 that could result from the impacts of the alternatives, combined with past, other present and 

28 reasonably foreseeable future actions. Unavoidable impacts, irreversible and irretrievable 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

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1 commitment of resources, and the relationship between short-term uses and long-term productivity 

2 are also discussed. 

3 Sections 7 and 8: These sections provide a list of this document’s preparers and references. 

4 Sections 9 and 10: These sections provide a glossary and index. 

5 Appendices: This PEIS includes 14 appendices (Volumes II and III) that provide additional 

6 information. 
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1 2. Alternatives 

2 2.1 Introduction 

3 This section discusses the alternatives to implement the proposed actions. As described in Section 

4 1.3.2 (Need for the Actions), NMFS is considering four proposed actions and alternatives to 

5 implement the proposed actions. The alternatives are grouped into the following six topics: SAs and 

6 response; carcass disposal; rehabilitation activities; release activities; disentanglement; and 

7 biomonitoring and research activities. The description of each topic includes the proposed action(s) 

8 that those alternatives would affect. Activities and Policies and Best Practices documents are 

9 described under each issue, where appropriate, to clarify the actions taken under each alternative. A 

10 No Action Alternative, Status Quo Alternative, and Preferred Alternative are designated under each 

11 issue. 

12 The No Action Alternative for each issue is based upon NMFS not undertaking the coordination and 

13 operation of the MMHSRP. Current SAs would not be renewed and new SAs would not be issued. 

14 The Policies and Best Practices manual and the ESA/MMPA permit would not be issued. The 

15 stranding and disentanglement networks would continue their current activities. As current SAs 

16 expired, the current National Stranding Network would cease to exist. Once the current ESA/MMPA 

17 permit expires on June 30, 2009, the current disentanglement network would no longer function. 

18 2.1.1 Stranding Agreements and Response Activities 

19 2.1.1.1 Response Activities 

20 Response activities analyzed in this PEIS are only those that are conducted by groups operating under 

21 the authority of a SA, MMPA Section 109(h) (state and local governments), or another legal means. 

22 Response to a dead stranded marine mammal may include beach assessment, collection of the 

23 carcass, field or laboratory necropsy, carcass disposal, and/or retention of parts and specimens. This 

24 may include the use of heavy machinery on or close to the beach in order to retrieve or move animals. 

25 Response to a live stranded marine mammal may include beach assessment, capture, relocation, 

26 transport to a rehabilitation facility, euthanasia, and/or release back to the wild. Pinnipeds on beaches 

27 are typically monitored for 24-48 hours before any response is taken to ensure that the animal truly is 

28 stranded and to avoid overcrowding at rehabilitation facilities. Solitary stranded animals are 

29 generally not refloated (i.e., released from the beach). It is assumed that a solitary animal stranded 

30 because it is unhealthy and if the animal is refloated, it is likely to strand again. For mass strandings, 
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Final Programmatic Environmental Impact Statement February 2009 

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1 most of the animals are likely to be healthy and may be refloated from the stranding site. These 

2 animals would be marked with some form of identification, in case they restrand. 

3 Live animal response may also include the administration of chemical agents (sedatives, antibiotics, 

4 euthanasia solution) or other veterinary intervention on the beach. All euthanasia procedures would 

5 follow the American Veterinary Medical Association (AVMA) guidelines (AVMA 2001) and/or the 

6 American Association of Zoo Veterinarians (AAZV) guidelines (AAZV 2006). While conducting a 

7 beach response, the stranding network member may cordon off or close areas of the beach to public 

8 access. All dead and live stranded animals are assessed for signs of human interaction. Human 

9 interactions include vessel interactions (e.g., propeller lacerations and blunt trauma), entanglements in 

10 fishing gear or marine debris, ingestion of gear and debris, and gun shots. Training is provided to the 

11 National Stranding Network on human interaction documentation to ensure consistency in reporting 

12 and aid in management decisions. 

13 Hazing of marine mammals may occur if an animal is in the vicinity of an oil or hazardous material 

14 spill, HABs, or sonar. Animals may also be hazed to deter a potential mass stranding. For all marine 

15 mammals, including threatened and endangered species, hazing is authorized under the MMHSRP’s 

16 ESA/MMPA permit. Hazing methods include, but are not limited to, the use of acoustic and visual 

17 deterrents, vessels, exclusion devices, and capture and relocation. Active and passive acoustic 

18 deterrents may be used to deter cetaceans. Pingers, which are typically used in the commercial 

19 fishing industry, produce high-frequency pulses of sound to deter animals. Passive deterrents include 

20 devices that provide a reflection of echolocation signals. Pinniped acoustic deterrents include bells, 

21 firecrackers, or starter pistols. Visual deterrents for pinnipeds include flags, streamers, and flashing 

22 lights. Vessels can be used to herd animals back out to open water or away from a hazardous 

23 situation. Exclusion devices for pinnipeds may include nets or fencing. Please see Appendix H for 

24 more detailed information on hazing methods. 

25 2.1.1.2 Stranding Agreement Template and Criteria 

26 While NMFS has issued SAs for many years, they have been in a variety of formats with a large 

27 amount of variability between regions. They have also differed significantly in the level of detail 

28 regarding the authorized activities of the agreement holder. The National Template for Marine 

29 Mammal SAs (see Appendix C) was developed to standardize the SA nationwide, while maintaining 

30 flexibility in certain areas to address differences in the NMFS regions. All sections that are in black 

31 are proposed to be implemented nationwide; the shaded sections are flexible and may be implemented 
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Final Programmatic Environmental Impact Statement February 2009 

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1 on a region-by-region basis. Flexible areas include reporting timelines for Level A data and 

2 additional reporting requirements (Level B and C data). The Template codifies the rights and 

3 responsibilities of both NMFS and the Stranding Network Participant. Different sections apply to 

4 different roles of stranding responders, and may be used independently or in conjunction with each 

5 other. For instance, a network member that only conducted dead animal response and necropsy 

6 activities would have Article III in their SA but not Article IV, V or VI, whereas a network member 

7 that responded to live and dead animals, and transported and rehabilitated live animals would have all 

8 Articles but VI, which corresponds to Designee organizations. One of the main differences between 

9 this template and previous versions utilized is Article IX, Section B, which sets out a procedure for 

10 probation, suspension, and eventual termination following repeated violations of the terms and 

11 conditions of the SA. 

12 The SA criteria are for new and renewal SA applicants (see Appendix C). The qualifications were 

13 designed to standardize SAs across the U.S., but allow for regional flexibility when necessary. For 

14 example, in areas that are geographically remote or have low stranding coverage, the evaluation 

15 criteria may be waived based on the discretion of the NMFS Regional Administrator. Qualifications 

16 are listed for response to dead stranded marine mammals/first response; response, triage, and 

17 transport of live stranded marine mammals; and rehabilitation and release of live stranded marine 

18 mammals. 

19 Stranding network participants must comply with the terms and responsibilities of their SAs through: 

20 (1) timely reporting of strandings to NMFS; (2) timely submission of complete reports on basic Level 

21 A data; (3) collection and timely reporting of additional information when feasible and requested by 

22 NMFS; and (4) cooperation with other network members as well as local, state, and Federal officials. 

23 2.1.1.3 Stranding Agreement and Response Alternatives 

24 The following alternatives address the stranding response activities of the stranding network and the 

25 SA criteria in the Policies and Best Practices manual. These alternatives would impact Proposed 

26 Actions 1, 2, 3, and 4. 

27 Alternative A1. No Action Alternative- SAs are not issued or renewed. No stranding 

28 response activities. 

29 Under Alternative A1, NMFS would not issue new SAs or renew current SAs. The SAs would expire 

30 and authorized stranding response activities would end. The current stranding network would cease 
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Final Programmatic Environmental Impact Statement February 2009 

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1 to exist. Federal (not including NMFS), state, and local agencies authorized under MMPA Section 

2 109(h) would still be able to conduct emergency response to non-ESA listed species, and ESA-listed 

3 species under regulations at 50 CFR 17.21(c)(3) and 17.31(a), where applicable. However, response 

4 activities would likely be limited and localized, and would consist mostly of carcass disposal for the 

5 protection of public health and safety. 

6 Alternative A2. Status Quo Alternative- Current SAs are renewed and current stranding 

7 response activities continue. Final SA criteria are not issued. 

8 Under Alternative A2, NMFS would renew the current SAs but would not issue new SAs. Current 

9 stranding response activities would continue but new activities would not be included. New SA 

10 holders could not be added to the network and other changes to the network would not occur. The 

11 final SA criteria would not be issued. SAs would continue to be issued regionally with national 

12 programmatic oversight. Standardization would not occur or proceed slowly with resultant 

13 inefficiencies which may impact accomplishment of agency mandates. 

14 Alternative A3. SAs are issued to any applicants after review. Final SA criteria are not 

15 issued. SAs include current and future stranding response activities. 

16 Under Alternative A3, NMFS would issue SAs to any applicants after they were reviewed by the 

17 NMFS Regional Office (including renewals). The final SA Criteria would not be implemented, and 

18 the new SA template would not be utilized. SAs would include current and future stranding response 

19 activities. 

20 Alternative A4. Preferred Alternative- Final SA criteria are implemented. SAs would be 

21 issued on a case-by-case basis. SAs include current and future stranding 

22 response activities. 

23 Under Alternative A4, NMFS would implement the final SA criteria and issue SAs on a case-by-case 

24 basis to those entities meeting the SA criteria (including renewals and new applicants), utilizing the 

25 new SA template. SAs would include current and future stranding response activities. This 

26 alternative would also allow modifications to stranding activities, including response procedures, 

27 tools and equipment, and euthanasia techniques. 
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1 Alternative A5. Final SA criteria are implemented. SAs would be issued on a case-by-case 

2 basis. Stranding response to threatened, endangered, and rare animals is 

3 required; response to other animals is optional. 

4 Under Alternative A5, NMFS would implement the final SA criteria and issue SAs on a case-by-case 

5 basis to those entities meeting the SA criteria (including renewals and new applicants), utilizing the 

6 new SA template. SAs include current and future stranding response activities, however this 

7 alternative would require response to threatened, endangered and rare animals as part of the terms and 

8 conditions of the SA. Response to all other animals would be optional, but highly encouraged. 

9 Stranding participants could respond to these non-listed animals when feasible, based upon the 

10 availability of resources. 

11 2.1.2 Carcass Disposal 

12 2.1.2.1 Carcass Disposal Methods 

13 During stranding response activities, carcass disposal methods depend on the species, the number and 

14 size of animals, location and logistics. Location includes coastal geography, currents, and state 

15 and/or local laws and regulations. Logistics refers to the availability of equipment, resources, and 

16 manpower. The method of carcass disposal will also be based upon the chemicals used on the animal, 

17 including antibiotics, sedatives, and/or euthanasia solution. 

18 One method of disposal is to leave the carcass where the stranding occurred. Natural decomposition, 

19 scavengers, and the tide will eventually dispose of the remains. Leaving the carcass on-site is 

20 possible in uninhabited areas. However it is less feasible in populated areas where the carcass may be 

21 a public health or aesthetic concern, or if chemicals were used to euthanize the animal. Another 

22 method of disposal is to move a carcass from an unsuitable area (public beach) to a more appropriate 

23 location (a remote beach or a landfill) and let it decompose. Carcasses may also be buried onsite or 

24 transported and buried in a more suitable location. A carcass can be towed out to sea and released, 

25 but the release site must be far enough from shore so the carcass will not wash up again. If a carcass 

26 returns to shore, it necessitates further response and disposal activities. A carcass can also be sunk by 

27 attaching materials, such as cement barriers or chains, to weigh the carcass down. 

28 Other industrial disposal methods include incinerating, rendering, and composting. The ability of the 

29 local stranding network to utilize these methods depends greatly on the resources available in their 

30 area and cost. Composting is an alternative method of carcass disposal involving transporting 
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1 carcasses to a composting facility. Composting is not commonly used at the present time, but it is 

2 being explored in an experiment conducted by the University of New England utilizing funding from 

3 a recent Prescott grant. This study will look at the efficiency of composting, as well as the retention 

4 rate of euthanasia solution, bacteria and viruses, and possibly contaminants, by comparing readings 

5 from the pre-composted carcasses and the resulting compost. 

6 2.1.2.2 Carcass Disposal Alternatives 

7 The following alternatives define different options for marine mammal carcass disposal. These 

8 alternatives would impact Proposed Actions 1 and 3. 

9 Alternative B1. No Action Alternative- No carcass disposal. 

10 Under Alternative B1, NMFS would terminate carcass disposal. Current SAs would expire and 

11 stranding response would cease; any disposal activities conducted by stranding network members 

12 would also cease. Carcasses of stranded animals would be left on-site to decompose or wash back out 

13 into the ocean. Federal (not including NMFS), state, and local agencies authorized under MMPA 

14 Section 109(h) would still be able to conduct carcass disposal of non-ESA listed species, and ESA15 listed species under regulations at 50 CFR 17.21(c)(3) and 17.31(a), where applicable for the 

16 protection of public health and safety. Their methods of carcass disposal and their impacts would not 

17 be covered under the MMHSRP. 

18 Alternative B2. Status Quo Alternative- Current methods of carcass disposal continue. 

19 Alternative B2 would continue the current carcass disposal methods used by stranding network 

20 members. 

21 Alternative B3. Preferred Alternative- Status Quo with the recommendation to transport 

22 chemically euthanized animal carcasses off-site. 

23 Under Alternative B3, NMFS would recommend the removal of chemically euthanized animal 

24 carcasses off-site for disposal by incineration, landfill, or other methods. Animals that die naturally 

25 or euthanized by other means may be disposed of by whatever means feasible and allowed, including 

26 those methods described in Section 2.1.2.1. Alternative B3 would allow the modification of carcass 

27 disposal activities as new information is obtained regarding persistent contaminants or as disposal 

28 methods are improved or developed, including composting. 
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1 2.1.3 Rehabilitation Activities 

2 2.1.3.1 Rehabilitation Facilities and Activities 

3 Twenty-nine facilities are currently authorized under SAs, the National Contingency Plan, or as 

4 NMFS designees to conduct marine mammal rehabilitation on species under NMFS jurisdiction (see 

5 Appendix F). These facilities are highly variable in terms of species treated, capacity, and facility 

6 amenities. Some rehabilitation is conducted in the open ocean, by using nets to fence off a bay or 

7 lagoon, or by using floating platforms with nets attached. Some facilities have elaborate structures 

8 including inground pools and underwater observation windows, while other groups have only 

9 aboveground or temporary pools, which are assembled only when needed. The length of time that a 

10 facility can rehabilitate an animal may depend on the species, medical needs, or the available 

11 equipment. Most rehabilitation activities conducted in temporary (“pop-up”) pools with or without 

12 external filtration units must be short-term (days or possibly weeks), and efforts focus primarily on 

13 stabilization and assessment. Other organizations are capable of long-term rehabilitation efforts of 

14 weeks or months, although usually at considerable cost (in both money and effort). Carcass disposal 

15 methods at rehabilitation facilities include rendering, incinerating, or burial in a landfill. 

16 Rehabilitation activities conducted by state or local government official in the normal course of their 

17 duties are covered by regulation at 50 CFR 216.22 (a)(3): “Where the marine mammal in question is 

18 injured or sick, it shall be permissible to place it in temporary captivity until such time as it is able to 

19 be returned to its natural habitat.” The governmental official is required to report to the Secretary of 

20 Commerce the activities under this section every six months details on the marine mammal take, 

21 including “the description of the place and means of confinement and the measures taken for its 

22 maintenance and care” when the animal has been retained in rehabilitation (50 CFR 216.22(b)(5)). 

23 2.1.3.2 Rehabilitation Facility Standards 

24 The Rehabilitation Facility Standards set minimum facility, husbandry, and veterinary standards for 

25 rehabilitating marine mammals to optimize the success of releasing the animals back to the wild (see 

26 Appendix C). The standards also address personnel health and safety issues and contingency 

27 planning. Some standards are based on the Animal Welfare Act regulations, which define minimum 

28 standards for captive marine mammals. Standards are also based on expert input from a 1998 NMFS 

29 workshop in Miami, Florida. Recommended standards (above the minimum) are included for facility 

30 design and operation and are suggestions for optimizing the rehabilitation success rate. Meeting or 
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1 exceeding the recommended standards may be considered a goal to strive towards when upgrading 

2 existing or designing new facilities or protocols. 

3 2.1.3.3 Rehabilitation Activities Alternatives 

4 The following alternatives address the rehabilitation activities of the stranding network and the 

5 Rehabilitation Facility Standards in the Policies and Best Practices manual. These alternatives would 

6 impact Proposed Actions 1, 2, 3, and 4. 

7 Alternative C1. No Action Alternative- No rehabilitation of stranded animals. 

8 Under Alternative C1, NMFS would terminate the rehabilitation of stranded animals. Current SAs 

9 would expire, stranding response would cease, and therefore animals would not be rehabilitated. Sick 

10 and injured animals would be left on the beach. 

11 Alternative C2. Status Quo Alternative- Current rehabilitation activities continue. 

12 Under Alternative C2, NMFS would continue the current rehabilitation activities of the stranding 

13 network. New rehabilitation facilities could not be added to the stranding network. Adaptive changes 

14 to rehabilitation activities would not be permitted. The final Rehabilitation Facility Standards would 

15 not be implemented. 

16 Alternative C3. Preferred Alternative- NMFS issues new SAs and response and rehabilitation 

17 activities continue. Final Rehabilitation Facility Standards are implemented. 

18 Under Alternative C3, NMFS would continue the current rehabilitation activities of the stranding 

19 network, with the ability to designate new rehabilitation facilities and modify rehabilitation activities 

20 if necessary. The final Rehabilitation Facility Standards would be implemented. 

21 Alternative C4. New SAs are issued and response and rehabilitation activities continue. 

22 Rehabilitation of threatened, endangered, and rare animals is required; 

23 response to other animals is optional. Final Rehabilitation Facility Standards 

24 are implemented. 

25 Under Alternative C4, NMFS would require the rehabilitation of stranded threatened, endangered, 

26 and rare animals. Rehabilitation of all other animals would be optional, but highly encouraged. 

27 Stranding participants could rehabilitate these animals when feasible, based upon the availability of 

28 resources. The final Rehabilitation Facility Standards would be implemented. 
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1 2.1.4 Release of Rehabilitated Animals 

2 2.1.4.1 Release Activities 

3 Release of a rehabilitated animal occurs when an attending veterinarian, after consultation with 

4 NMFS, determines the animal is releasable. The presumption and goals for rehabilitated animals are 

5 to release them back to the wild. In some cases, releasing a rehabilitated animal may not be the best 

6 solution for either the individual animal or its conspecifics (members of the same species). The 

7 minimum protocols for the release of a rehabilitated marine mammal are covered under regulation at 

8 50 CFR 216.27. Every six months, the marine mammal must be evaluated for releasability by the 

9 attending veterinarian. The release determination recommendation and a release plan are made by the 

10 attending veterinarian of the rehabilitation facility, in consultation with their assessment and/or 

11 husbandry team. This plan includes: 1) a description of the marine mammal, including its physical 

12 condition and estimated age; 2) the date and location of the proposed release; and 3) the method and 

13 duration of transport prior to release, per 50 CFR 216.67 (a)(2)(ii). The recommendation and release 

14 plan are reviewed and approved or changed, if necessary, by NMFS prior to a release. The release 

15 recommendation and plan are provided to NMFS at least 15 days in advance of a proposed release 

16 date. The NMFS Regional Administrator may allow for pre-approved waivers for routine pinniped 

17 cases as stated in 50 CFR 216.27(a)(2)(i)(A). This allows for the release of animals without the 

18 required 15-day advanced notice or detailed release plan for an individual case. Typically these 

19 waivers apply to cases involving routine diagnosis (i.e., known cause of stranding), treatment, and 

20 rehabilitation. Such waivers require the rehabilitation facility to submit a treatment and release 

21 protocol for approval. Waivers are not considered for cetacean cases. Non-releasable animals may, 

22 with NMFS approval, be permanently placed in a public display or scientific research facility, or may 

23 be euthanized. 

24 Prior to release, NMFS requires that animals be tagged or marked for individual identification, and 

25 the tag number or description of the marking reported to NMFS. Current commonly used forms of 

26 identification for cetaceans include photo identification, freeze branding, and/or a dorsal fin tag. 

27 Photo identification should include the body, face, dorsal fin, flukes, and pectoral flippers, as well as 

28 any identifying characteristics such as scars or color pattern markings. A numerical freeze brand (if 

29 applicable) would be placed on both sides of the dorsal fin or just below the dorsal fin. Roto-tags 

30 would be attached on the trailing edge of the dorsal fin. Identification of non-delphinid cetaceans is 

31 determined in consultation with NMFS. NMFS must also approve any additional forms of 

32 identification to be attached, such as VHF or satellite tags. All pinnipeds must be flipper tagged for 
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1 identification. Tags and placement instructions would be obtained from NMFS as appropriate for the 

2 pinniped species. Other identification methods, such as freeze branding or glue tags, may be used in 

3 addition to flipper tags. The identification method is detailed in the release plan, and will be 

4 approved by NMFS prior to being implemented, especially if unique or atypical methods are utilized. 

5 Cetaceans are transported to release sites by vessel. Pinnipeds are transported via vehicle or vessel to 

6 beach or ocean release sites. Post-release monitoring is conducted for all released animals. Post7 release monitoring may be conducted using mark-resight methodology, radio telemetry, or satellite 

8 tags. Monitoring should continue on a regular basis for at least one full year or, at a minimum, the 

9 battery duration of the tag. 

10 2.1.4.2 Release Criteria 

11 The release criteria provide guidance for determining the release of rehabilitated marine mammals to 

12 the wild (see Appendix C). The guidance includes marine mammal species under NMFS and 

13 USFWS jurisdiction. It is a joint document developed by NMFS and USFWS in consultation with 

14 marine mammal experts. Standards are also based upon review and public comment of the 1997 draft 

15 NOAA Technical Memorandum “Release of Stranded Marine Mammals to the Wild: Background, 

16 Preparation, and Release Criteria.” The standards provide recommendations for the medical, 

17 behavioral, and developmental assessment of rehabilitated animals prior to release. 

18 Recommendations on release site selection and post-release monitoring are also included. The 

19 release criteria also require a health screen and certification before an animal is released. 

20 2.1.4.3 Release Alternatives 

21 The following alternatives address the release activities of the stranding network and the release 

22 criteria in the Policies and Practices manual. These alternatives would impact Proposed Actions 1, 2, 

23 3, and 4. 

24 Alternative D1. No Action Alternative- No animals to be released. 

25 Under Alternative D1, NMFS would end the release of stranded animals. Current SAs would expire, 

26 stranding response and rehabilitation would cease, and therefore there would be no animals to release. 

27 Alternative D2. Status Quo Alternative- Current release activities continue. 
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1 Under Alternative D2, NMFS would continue the current release activities of the stranding network. 

2 Adaptive changes to release activities would not be permitted. The final release criteria would not be 

3 implemented. 

4 Alternative D3. Preferred Alternative- New SAs are issued and response, rehabilitation, and 

5 release activities continue. Final release criteria would be implemented and 

6 would include adaptive management of release activities. 

7 Under Alternative D3, NMFS would continue the current release activities of the stranding network, 

8 with the ability to modify release activities (adaptive changes) when necessary. The final release 

9 criteria would be implemented. 

10 2.1.5 Disentanglement Network 

11 2.1.5.1 Disentanglement Activities 

12 Disentanglement efforts are conducted for many marine mammals. For large whales, 

13 disentanglement efforts may include vessel and aerial searches for the affected animal and incidental 

14 harassment of non-entangled animals during these searches. Close approaches, tagging, use of buoys 

15 or sea anchors to slow an animal’s movement, cutting of lines and possibly flesh (when the line is 

16 embedded), and remote sedation may occur during disentanglement. For pinnipeds and small 

17 cetaceans, disentanglement efforts may include capture with incidental disturbance of non-entangled 

18 animals, restraint, surgery, rehabilitation, administration of chemical agents (sedatives and/or 

19 antibiotics), and release. Biopsy sampling may occur, either through the use of a remote dart or the 

20 collection of tissues from the removed fishing gear. Appendix H contains the general methodologies 

21 used during disentanglement activities. All disentanglement activities of ESA-listed species are 

22 authorized under the ESA/MMPA permit; disentanglement of non-listed species are conducted under 

23 the authority of the SA. 

24 2.1.5.2 Disentanglement Guidelines 

25 The Marine Mammal Disentanglement Guidelines provide the definitions and roles for First 

26 Responders, Primary First Responders, and Primary Disentanglers for large whale disentanglements 

27 (see Appendix C). The five levels of responders are described, including the targeted individuals, 

28 responsibilities, and the criteria to be certified for each level. A First Responder is anyone in the 

29 disentanglement network with any level of training who may respond to an entanglement report under 

30 network protocols and authorization. A Primary First Responder is an individual with a higher 
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1 network classification (Levels 3-5) that may direct efforts locally and, under certain conditions and 

2 authorization, may attempt disentanglements during first response. A Primary Disentangler is an 

3 individual who can perform all the duties of a First Responder, but also meets the NMFS criteria to 

4 undertake the actual disentangling. Primary Disentanglers have a classification of Level 4 or 5 in the 

5 network. Under the direction of the NMFS Disentanglement Coordinator, these Guidelines are 

6 currently in use for the Disentanglement Network on the East Coast (both NMFS Northeast and 

7 Southeast Regions). There are approximately 165 trained members of the disentanglement network 

8 with response levels ranging from 2-5. There are several hundred more members that have been 

9 trained at response level 1. 

10 There are no standardized protocols for disentanglement of small cetaceans and pinnipeds. Currently, 

11 these animals are approached on a case-by-case basis by members of the stranding network, 

12 responding to them as they would to any other stranded animal. Response to entangled small 

13 cetaceans typically requires in-water capture of free-swimming animals. Some animals may have 

14 impaired locomotion if the gear is heavy or anchored. Entangled pinnipeds are typically captured on 

15 land when they are hauled out. Animals may be freed of gear and immediately released, or brought 

16 into a rehabilitation facility for a period of time prior to release. 

17 2.1.5.3 Disentanglement Alternatives 

18 The following alternatives address the disentanglement network and the Disentanglement Guidelines 

19 in the Policies and Practices manual. These alternatives would impact Proposed Actions 1, 2, 3, and 

20 4. 

21 Alternative E1. No Action Alternative- No disentanglement network. 

22 Under Alternative E1, NMFS would terminate the disentanglement network. The current SAs would 

23 expire and pinniped and small cetacean disentanglement would end. The current ESA/MMPA permit 

24 would expire and disentanglement activities of ESA-listed species would not be authorized. 

25 Entangled animals may be monitored, (as long as they were not harassed during the monitoring 

26 activities), but no action would be taken to disentangle them. 

27 Alternative E2. Status Quo Alternative- Disentanglement network continues current 

28 activities, no modifications or new members added. 
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1 Under Alternative E2, NMFS would continue the current activities of the disentanglement network. 

2 Current SAs would continue to allow disentanglement of pinnipeds and small cetaceans. The new 

3 ESA/MMPA permit would be issued and would authorize the current disentanglement activities for 

4 ESA-listed species. New members could not be added to the disentanglement network. Adaptive 

5 changes to disentanglement activities, including the use of newly developed equipment, would not be 

6 permitted. 

7 Alternative E3. Preferred Alternative- Disentanglement network continues current activities 

8 on East Coast with modifications to West Coast network. The 

9 Disentanglement Guidelines and training prerequisites would be 

10 implemented. 

11 Under Alternative E3, NMFS would continue the current activities of the disentanglement network, 

12 with the ability to add new participants and modify disentanglement activities and technologies when 

13 necessary. Current and future SAs would continue to allow disentanglement of pinnipeds and small 

14 cetaceans. The new ESA/MMPA permit would be issued and would authorize the current and future 

15 disentanglement activities of ESA-listed species. The East Coast network would continue their 

16 current activities. Modifications would be made to the West Coast network to coordinate the 

17 structure and training with the East Coast network. The Disentanglement Guidelines and training 

18 prerequisites for network participants would be implemented nationwide. 

19 2.1.6 Biomonitoring and Research 

20 2.1.6.1 Biomonitoring and Research Activities 

21 The MMHSRP conducts and sponsors a variety of prospective health assessments and research 

22 projects relating to marine mammal health. The prospective health assessment research activities of 

23 the MMHSRP are conducted on stranded animals and free-ranging animals that occur in areas with 

24 known health concerns or in areas of previous health concerns. Marine mammals that are captured 

25 for these health assessments may have visible health problems (for example, skin lesions), they may 

26 have been exposed to known toxins, or they may have been exposed to other physical, chemical, or 

27 biotic stressors that are known to produce adverse health outcomes in marine mammals. The areas 

28 targeted for prospective health assessments often include areas of previous and current die-offs. 

29 Many different diagnostic and research labs are under permit and/or contract with the MMSHRP to 

30 provide analyses. Services provided include histopathology, virology, bacteriology, toxicology 
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1 (contaminant and biotoxin analyses), and acoustic diagnostics. General research methodologies are 

2 described in Appendix H. 

3 2.1.6.2 Biomonitoring and Research Alternatives 

4 The following alternatives address the biomonitoring and research activities of the MMHSRP. These 

5 alternatives would impact Proposed Actions 2 and 3. 

6 Alternative F1. No Action Alternative- Biomonitoring and research activities would not 

7 occur. 

8 Under Alternative F1, NMFS would terminate the current biomonitoring and research activities of the 

9 MMHSRP. This would include the NMMTB, health assessment captures, and other various research 

10 projects. 

11 Alternative F2. Status Quo Alternative- Continuation of current biomonitoring and research 

12 activities. 

13 Under Alternative F2, NMFS PR1 would issue the MMHSRP a new ESA/MMPA permit that would 

14 include the current biomonitoring and research activities. New biomonitoring and research activities 

15 would not be added under the permit. 

16 Alternative F3. Preferred Alternative- New ESA/MMPA permit issued to include current and 

17 future biomonitoring and research activities. 

18 Under Alternative F3, NMFS PR1 would issue the MMHSRP a new ESA/MMPA permit that would 

19 include current and new biomonitoring and research activities. 

20 2.2 Alternatives Considered but Eliminated from Further Analysis 

21 2.2.1 Stranding Response Alternatives 

22 Stranding Response Curtailed Immediately. This alternative would immediately stop the response 

23 to stranded animals and the current stranding network would cease to exist. Public comments 

24 supported the continuation of stranding response activities and stated that this alternative was not 

25 feasible. Under this alternative, NMFS would not be fulfilling its mandate under the MMPA, and 

26 there would be a high level of public controversy. Therefore, NMFS eliminated this alternative. 
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1 Stranding Response to Some Animals is Authorized, Other Animals are Prohibited. Public 

2 comments did not support prohibiting stranding response to certain animals. By denying 

3 organizations the ability to respond to some animals, these animals would have to be left on the 

4 beach. This would create public controversy, and would eliminate valuable information on marine 

5 mammal health and populations that is gained from the examination of stranded animals. Therefore, 

6 NMFS eliminated this alternative. 

7 2.2.2 Carcass Disposal Alternatives 

8 All Animals are Buried On-site. Burial is not an option in all geographic areas due to substrate 

9 issues (rocks or dense soil, shallow water table, inaccessibility by necessary machinery, etc.) or local 

10 restrictions. Burial of animal carcasses may be prohibited in some areas where animals strand. In 

11 addition, marine mammal carcasses have the potential to be highly toxic. Chemically euthanized 

12 animal carcasses may contain high concentrations of lethal chemicals. Other carcasses may have high 

13 toxin levels from biotoxins or other contaminants. Burying these carcasses would create a risk to 

14 scavengers, water quality, and soils. The option to transport carcasses off-site must be available. 

15 Therefore, NMFS eliminated this alternative. 

16 All Animals are Transported Off-site for Disposal. Public comments did not support the alternative 

17 to transport all carcasses off-site for disposal. Transporting all carcasses off-site would place a 

18 financial burden on stranding network participants. In addition, some carcasses may not be 

19 transportable for logistical reasons: the animal is too large or too heavy to lift; equipment is 

20 unavailable or cost prohibitive; equipment is not permitted; or has no available beach access. Other 

21 disposal methods (burial, disposal at sea, natural decomposition) for non-toxic carcasses are more 

22 cost-effective and feasible. Therefore, NMFS eliminated this alternative. 

23 No Animals are Chemically Euthanized. Chemical injection is currently the most common humane 

24 method of euthanasia for pinnipeds and small cetaceans. Other methods of euthanasia, such as 

25 ballistics (shooting) or explosives, may be dangerous to personnel assisting with the process as well 

26 as the public. Prohibiting the use of chemical euthanasia would require stranding personnel to either 

27 use these methods or not perform euthanasia. The use of other methods would increase the risks to 

28 human health and safety. Additional numbers of animals would be killed using other means or left on 

29 the beach to die, which could increase the suffering of the animal and potentially create public 

30 controversy. Therefore, NMFS eliminated this alternative. 
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1 2.2.3 Rehabilitation Activities Alternatives 

2 Rehabilitation Activities Curtailed Immediately. This alternative would immediately stop the 

3 rehabilitation of stranded animals. Public comments supported the continuation of rehabilitation 

4 activities and stated that this alternative was not feasible. Under this alternative, NMFS would not be 

5 fulfilling its mandate under the MMPA. Therefore, NMFS eliminated this alternative. 

6 Rehabilitation of Some Animals is Authorized, Other Animals are Prohibited. Public comments did 

7 not support prohibiting the rehabilitation of certain animals. By denying organizations the ability to 

8 respond to some animals, these animals would have to be left on the beach. This would create public 

9 controversy, and would eliminate valuable information on marine mammal health and populations. 

10 Rehabilitation of common species also gives rehabilitation facilities additional opportunities to 

11 perfect their rehabilitation practices, increasing the chance of successful rehabilitation and release of 

12 threatened, endangered and rare species. Therefore, NMFS eliminated this alternative.

13 2.2.4 Release of Rehabilitated Animals Alternatives 

14 All Animals are Released (After Rehabilitation). Currently, nonreleasable animals may be placed in 

15 permanent captivity in a public display or at a research facility if they hold an APHIS exhibitor’s or 

16 research license. During rehabilitation, problems may be detected that would prevent the animal from 

17 being deemed releaseable (e.g., the animal has a medical issue requiring regular veterinary care and 

18 medications, or it develops behavioral problems). Requiring the facility to release this animal despite 

19 this condition would be detrimental to the welfare of the animal and possibly to the wild population 

20 and human safety. Therefore, NMFS eliminated this alternative. 

21 Release of Some Animals is Required, Other Animals are Optional. Under this alternative, release 

22 of some species of rehabilitated animals would be required to occur under any circumstance, or the 

23 animal would be euthanized. Currently, these animals may be deemed nonreleaseable and placed in 

24 permanent captivity at a public display or at a research facility, where they contribute to the education 

25 of the general public or to the scientific body of knowledge. Requiring the release of animals would 

26 result in the release of inappropriate animals (those suffering from medical or behavioral conditions). 

27 This would be detrimental to the welfare of the animals and possibly to the wild population and 

28 human safety. Therefore, NMFS eliminated this alternative.

29 Release of Some Animals is Authorized, Other Animals are Prohibited. Under this alternative, 

30 release of some species of rehabilitated animals would be prohibited, regardless of the circumstances. 
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1 Therefore, the animal would be placed in permanent captivity at a public display or at a research 

2 facility or euthanized, even if it was “releaseable” or appropriate to be released back into the wild. 

3 This would be a detriment to the wild population and would result in overcrowding at facilities, or 

4 needless euthanasia. Therefore, NMFS eliminated this alternative. 

5 2.2.5 Disentanglement Alternative 

6 Disentanglement of Some Animals is Authorized, Other Animals are Prohibited. Under this 

7 alternative, disentanglement of some species would be prohibited, regardless of the circumstances. 

8 Therefore, the animal would remain entangled and potentially unable to feed, swim, or reproduce, 

9 even if the entanglement could be dealt with at minimum risk to the animal and the response team 

10 This would be a detriment to the wild population and would result in needless death and suffering of 

11 marine mammals. Therefore, NMFS eliminated this alternative. 

12 2.2.6 Biomonitoring and Research Activities Alternatives 

13 Health Assessment Captures Would Not Occur. Under Title IV of the MMPA, one of the purposes 

14 of the MMHSRP is to collect and disseminate reference data on the health and health trends of marine 

15 mammal populations in the wild. Health assessment captures are an integral part of collecting this 

16 health reference data. Captures are also used to provide information on animals in areas where UMEs 

17 have occurred or are occurring, and significantly contribute to UME investigations. Therefore, 

18 NMFS eliminated this alternative. 

19 Tissue Banking Would Not Occur. The NMMTB was established under Title IV of the MMPA to 

20 store, analyze, and archive marine mammal tissues. Without the NMMTB, reference data on the 

21 health of marine mammals and populations of marine mammals would not be collected and 

22 maintained. Under this alternative, NMFS would not be fulfilling its statutory mandate to maintain 

23 the NMMTB. Therefore, NMFS eliminated this alternative. 
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3-1 

1 3. Affected Environment 

2 3.1 Introduction 

3 This chapter describes the environmental and socioeconomic conditions most likely to be affected by 

4 the alternatives. The information serves as a baseline from which to identify and evaluate potential 

5 impacts from implementation of the alternatives. In compliance with NEPA, CEQ, and NOAA 

6 regulations and guidelines, the description of the affected environment focuses on those resource 

7 areas that are potentially subject to impacts from the anticipated actions. These resources include: 

8 • Biological resources: protected and sensitive habitats, submerged aquatic vegetation (SAV) 

9 and macroalgae, sea turtles, marine mammals, threatened and endangered species, fish, birds, 

10 and other wildlife; 

11 • Water and sediment quality; 

12 • Human health and safety; 

13 • Cultural resources; and 

14 • Socioeconomics. 

15 Some environmental resources and conditions that are often analyzed in an EIS have been omitted 

16 from this analysis. Effects in the following categories are considered insignificant or irrelevant to the 

17 anticipated actions, or impacts from the alternatives are not anticipated: 

18 • Air quality: Air quality impacts from any individual activity would either be non-existent or 

19 minor (such as limited dust or emissions from a vehicle or boat engine). The impacts would 

20 be insignificant contributions when compared to impacts from other motor vehicle emissions 

21 on highways and roads where MMHSRP activity is occurring, and would not represent a 

22 significant contribution to regional air quality. Pathogen spread through treatment or 

23 necropsy of sick animals would not be considered air pollution, but is analyzed under human 

24 health and safety. 

25 • Noise: Most MMHSRP activities would not result in the production of noise. One exception 

26 would be the use of heavy machinery in response or disposal activities. However, this 

27 equipment would produce noise similar to or below levels that are allowed under local 

28 ordinances governing normal construction activities, and would be of short duration and 

29 extremely localized, and therefore resulting in insignificant impacts. 
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1 • Land use: The activities of the MMHSRP would not involve significant changes in land use 

2 or be inconsistent with existing local and regional plans and policies on land use. The land 

3 where response activities would occur is not considered suitable for agricultural use or 

4 housing development. 

5 • Public services and utilities: Public services include transportation, police, fire, and other 

6 emergency services. Utilities include electric power, gas/steam/oil, telecommunications, 

7 water facilities, storm drainage, and sanitary sewer systems. The MMHSRP’s activities 

8 would not disrupt, damage, or incur any other impact to these areas.

9 • Coastal zone management: NMFS has determined that the alternatives for the MMHSRP’s 

10 activities are consistent with the coastal management programs in the affected area. No 

11 significant impacts would be expected from these activities. 

12 3.2 Biological Resources 

13 3.2.1 Definition of the Resource 

14 Biological resources include native or naturalized plants and animals, and the habitats in which they 

15 exist. Sensitive and protected biological resources include plant and animal species listed as 

16 threatened or endangered by NMFS, USFWS, or that are otherwise protected under Federal or state 

17 laws. Resources evaluated include protected and sensitive habitats; SAV and macroalgae; sea turtles; 

18 fish and shellfish; coastal and marine birds; and marine mammals. 

19 Protected and Sensitive Habitats 

20 Protected and sensitive habitats are usually defined as those areas that are identified as marine 

21 sanctuaries, national seashores, critical habitats, coral reefs, national parks, wildlife refuges, national 

22 forests, national monuments, estuarine research reserve sites, and fisheries management areas. These 

23 particular areas are under Federal jurisdiction and are managed by NMFS, USFWS, the National Park 

24 Service (NPS), the National Ocean Service, the Bureau of Land Management (BLM), and the U.S. 

25 Forest Service (USFS). Wilderness areas are typically designated within current national parks, 

26 national wildlife refuges (NWR), national forests, and national monuments. Jurisdiction over 

27 wilderness areas is divided between USFWS, NPS, BLM, and USFS. Sensitive habitats may also be 

28 protected under State and local jurisdictions, including protected reserves, parks, beaches, and 

29 seashores. Executive Order (EO) 13089, Coral Reef Protection requires federal agencies, whose 

30 actions may affect U.S. coral reef systems, to identify those actions and ensure that they will not 

31 degrade the conditions of such ecosystems. Coral reefs are colonial invertebrates that excrete a 
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1 calcium carbonate skeleton. Coral reefs provide habitat to a reef fish and invertebrates, increase 

2 biodiversity, and protect shorelines from coastal erosion. Coral reefs support commercial and 

3 recreational fishing, boating, scuba diving, and pharmaceutical research. 

4 SAV and Macroalgae 

5 The term SAV refers to rooted, vascular, flowering plants that live and grow below the water surface 

6 (Stephan et al. 2000). SAV includes seagrasses and macrophytes (aquatic plants not rooted to a 

7 substrate). Macroalgae, such as seaweed and kelp, are multicellular algae large enough to be visible 

8 to the eye. SAV and macroalgae are among the most productive ecosystems in the world. Both occur 

9 in all U.S. coastal waters, with the exception of South Carolina and Georgia, where turbidity and tidal 

10 amplitude inhibit SAV growth (Stephan et al. 2000). SAV and macroalgae provide food and habitat 

11 for a variety of organisms, including important commercial and recreational fisheries species. SAV 

12 improves water quality, filters nutrients and contaminants, provides sediment stabilization, and 

13 reduces coastal erosion (GMP 2004). 

14 Marine Mammals and Sea Turtles 

15 The mission of NMFS is to manage, conserve, and protect all living marine resources within the U.S. 

16 EEZ, including marine mammals and sea turtles. Threatened and endangered marine mammals and 

17 sea turtles are protected under the ESA. Fifteen marine mammal species (or stocks of species) within 

18 the U.S. are listed under the ESA, and 7 foreign species are listed. Six sea turtle species within the 

19 U.S. are listed under the ESA, and 2 foreign species are listed. All marine mammals are protected 

20 under the MMPA. Some populations of marine mammals are designated as depleted under the 

21 MMPA. Twenty-six species, or stocks of species, have been listed as depleted. 

22 The ESA (16 U.S.C. 1531–1534), administered by NMFS and USFWS, mandates the protection and 

23 conservation of threatened and endangered species and the ecosystems on which they depend. Under 

24 the ESA, an “endangered species” is defined as any species in danger of extinction throughout all or a 

25 significant portion of its range. A “threatened species” is defined as any species likely to become an 

26 endangered species in the foreseeable future. “ESA Candidate species” are those that have been 

27 petitioned to be listed as threatened or endangered. Critical habitat may also be designated for 

28 threatened and endangered species. Critical habitat is defined as specific areas within the 

29 geographical area occupied by a species at the time of listing, if the areas contain physical or 

30 biological features essential to conservation, and those features may require special management 

31 considerations or protection. Specific areas outside the geographical area occupied by the species 
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1 may also be designated as critical habitat, if it is determined that the area is essential for conservation. 

2 Section 7 of the ESA requires that all Federal agencies consult with NMFS or USFWS, as applicable, 

3 before initiating any action that could affect a listed species. Under Section 7, a Federal agency must 

4 ensure that any project authorized, funded, or conducted by that agency is “...not likely to jeopardize 

5 the continued existence of any endangered species or threatened species or result in the destruction or 

6 adverse modification of habitat of such species which is determined to be critical.” All six species of 

7 sea turtles occurring in the U.S. are protected under the ESA. Federal protection of sea turtles is split 

8 between NMFS and USFWS. NMFS has the lead responsibility for the conservation and recovery of 

9 sea turtles in the marine environment. USFWS has the lead responsibility for sea turtles on nesting 

10 beaches. 

11 The MMPA (16 U.S.C. 1361 et seq.) protects all marine mammals, regardless of whether or not they 

12 are listed under the ESA. The Secretary of Commerce is responsible for the protection of all 

13 cetaceans (whales, porpoises, and dolphins) and pinnipeds (seals and sea lions), except walruses, and 

14 has delegated authority for implementing the MMPA to NMFS. The Secretary of the Interior is 

15 responsible for the protection of walruses, polar bears, sea otters, manatees, and dugongs, and has 

16 delegated this responsibility to the USFWS. These responsibilities include providing oversight and 

17 advice to regulatory agencies on all Federal actions that might affect these species. Marine mammals 

18 may be designated as “depleted” under the MMPA if the Secretary of Commerce, after consultation 

19 with the MMC, determines that the species or population stock is below its optimum sustainable 

20 population. Marine mammals that are listed as threatened or endangered under the ESA are also 

21 designated as depleted under the MMPA. 

22 The ESA prohibits the “take” of threatened and endangered species, with certain exceptions, within 

23 the U.S, in waters under U.S. jurisdiction, and by U.S. citizens on the high seas. Under Section 3 of 

24 the ESA, “take” is defined as “to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or 

25 collect, or to attempt to engage in any such conduct.” Exceptions are permitted for activities that are 

26 for scientific purposes or to enhance the propagation or survival of the affected species [Section 

27 10(a)(1)(A)] or for activities where the take would be incidental to an otherwise lawful activity 

28 [Section 10(a)(1)(B)]. Permits may be issued after submission, review, and a public comment period 

29 of an application and conservation plan, provided that the impacts of the take will be minimized to the 

30 maximum extent practicable. The taking must not appreciably reduce the likelihood of the survival 

31 and recovery of the species in the wild. Since 1999, the MMSHRP has obtained a 10(a)(1)(A) permit 
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1 for directed research and enhancement (including response and rehabilitation) of endangered species 

2 (Appendix G). 

3 The MMPA prohibits the “take” of marine mammals, with certain exceptions, in waters under U.S. 

4 jurisdiction and by U.S. citizens on the high seas. Under Section 3 of the MMPA, “take” of marine 

5 mammals is defined as “to harass, hunt, capture, or kill, or attempt to harass, hunt, capture, or kill any 

6 marine mammal.” “Harassment” is defined as any act of pursuit, torment, or annoyance that has the 

7 potential to injure marine mammal stock in the wild, or that has the potential to disturb a marine 

8 mammal or marine mammal stock in the wild by disrupting behavioral patterns, including migration, 

9 breathing, nursing, breeding, feeding, and sheltering. The Secretary of Commerce may issue permits 

10 which authorize the direct taking of marine mammals for scientific research, importation for public 

11 display, and the enhancement of the survival or recovery of a species or stock under Section 104 of 

12 the MMPA. Permits may also be issued for photography of marine mammals for educational or 

13 commercial purposes. Since 1999, the MMHSRP has obtained an MMPA permit for directed take of 

14 marine mammals (Appendix G). 

15 Fish, Shellfish, and EFH 

16 The ESA provides protection for threatened and endangered fish and shellfish species. The ESA 

17 allows the listing of distinct population segments (DPS) of threatened and endangered species. 

18 NMFS policy stipulates that a salmon population will be considered “distinct” for purposes of the 

19 ESA if it represents an Evolutionarily Significant Unit (ESU) of the biological species. To qualify as 

20 an ESU, a population (or group of populations) must be (a) reproductively isolated from populations 

21 of the same species, and (b) represent an important component in the evolutionary legacy of the 

22 species. 

23 Pursuant to Section 303(a) (7) of the Magnuson-Stevens Fishery Conservation and Management Act, 

24 regional fishery management councils must identify EFH used by all life history stages of each 

25 managed species. EFH is defined as waters and substrate that are necessary to the species for 

26 spawning, breeding, feeding, or growth to maturity. EFH that provides extremely important 

27 ecological functions or are particularly vulnerable to degradation should be identified as habitat areas 

28 of particular concern in order to prioritize conservation efforts. Activities that have been shown to 

29 affect EFH include disturbance or destruction of habitat from stationary fishing gear, dredging and 

30 filling, agricultural and urban runoff, direct discharge, and the introduction of exotic species. 

31 Consultation with NMFS is required if a proposed action permitted, funded, or undertaken by a 
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1 Federal agency could adversely affect EFH. When a Federal agency determines that an action may 

2 adversely affect EFH, the agency must initiate consultation with NMFS. The Federal agency must 

3 submit to NMFS an EFH assessment containing “a description of the action; an analysis of the 

4 potential adverse effects of the action on EFH and the managed species; the federal agency’s 

5 conclusions regarding the effects of the action on EFH; and proposed mitigation, if applicable.” For 

6 this PEIS, consultation with NMFS was initiated on June 22, 2006. An EFH Assessment was 

7 completed in March 2008. The consultation determined that impacts to EFH would not be expected 

8 to occur, with mitigation, as a result of the Proposed Actions and alternatives; therefore EFH will not 

9 be discussed further. 

10 Coastal and Marine Birds 

11 The ESA provides protection for threatened and endangered bird species. The Migratory Bird Treaty 

12 Act and EO 13186, Responsibilities of Federal Agencies to Protect Migratory Birds, provide 

13 protection for all migrating bird populations. Under these regulations, NMFS is required to analyze 

14 the potential impacts its actions may have on threatened, endangered, and migratory birds. 

15 3.2.2 Affected Environment 

16 3.2.2.1 Protected and Sensitive Habitats 

17 Atlantic Coast federally protected and sensitive habitats include 14 National Estuarine Research 

18 Reserves (NERRs), 69 National Wildlife Refuges (NWRs), 5 National Marine Sanctuaries (NMSs), 5 

19 national parks, 8 national seashores, 10 wilderness areas, and 1 ecological preserve (DOC/NOAA and 

20 DOI 2006, Wilderness.net 2006). Critical habitat has been designated for the North Atlantic right 

21 whale (Eubalaena glacialis), West Indian manatee, piping plover (Charadrius melodus), yellow22 shouldered blackbird (Agelaius xanthomus), green sea turtle (Chelonia mydas), leatherback sea turtle 

23 (Dermochelys coriacea), hawksbill sea turtle (Eretmochelys imbricata), and Johnson’s seagrass 

24 (Halophila johnsonii) (Appendix E, Table E-1). 

25 There are 39 designated coral reefs ranging from the southern tip of South Carolina to the Upper 

26 Florida Keys. Gray’s Reef, located off of Sapelo Island, GA, is one of the largest nearshore live27 bottom reefs in the southeastern U.S. Fifty-four coral reefs are located within Puerto Rico and the 

28 U.S. Virgin Islands. The staghorn coral (Acropora cervicornis) and elkhorn coral (Acropora 

29 palmata) are the first coral species to be listed as threatened under the ESA (Appendix E, Table E-5). 

30 These corals are the dominant reef building species and occur through out Florida, the Bahamas, and 

31 the Caribbean. Elkhorn and staghorn coral are found in shallow water reefs in high energy zones. In 
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1 the action area, the corals occur in the Florida Keys, Puerto Rico, and the U.S. Virgin Islands. 

2 Current threats to the species are pollution, excess nutrients, pathogens, climate change, and 

3 overfishing (NMFS 2006a). 

4 Gulf of Mexico federally protected and sensitive habitats include 5 NERRs, 32 NWRs, 1 NMS, 1 

5 national park, 2 national seashores, and 7 wilderness areas (DOC/NOAA and DOI 2006, 

6 Wilderness.net 2006). Critical habitat has been designated for the West Indian manatee, Gulf 

7 sturgeon (Acipenser oxyrhynchus desotoi), and whooping crane (Grus americana). Thirty-two coral 

8 reefs are located in the Gulf of Mexico, including the Florida Middle Grounds and the Flower Garden 

9 Banks, the northernmost coral reefs in North America (Appendix E, Table E-2). 

10 Pacific Coast federally protected and sensitive habitats include 6 NERRs, 34 NWRs, 5 NMSs, 1 

11 national seashore, 2 national parks, 5 national monuments, 5 national forests, 34 wilderness areas, and 

12 1 Steller sea lion conservation area (DOC/NOAA and DOI 2006, Wilderness.net 2006). Critical 

13 habitat has been designated for the following species: Steller sea lion, North Pacific right whale, 

14 Southern Resident killer whale DPS, tidewater goby (Eucyclogobius newberryi), Western snowy 

15 plover (Charadrius alexandrinus nivosus), Coastal California gnatcatcher (Polioptila californica 

16 californica), spectacled eider (Somateria fischeri), Steller’s eider (Polysticta stelleri), marbled 

17 murrelet (Brachyramphus marmoratus marmoratus), three coho salmon (Oncorhynchus kisutch) 

18 ESUs, five chinook salmon (Oncorhynchus tshawytscha) ESUs, two chum salmon (Oncorhynchus 

19 keta) ESUs, and four steelhead (Oncorhynchus mykiss) ESUs (Appendix E, Table E-3). 

20 Pacific Islands federally protected and sensitive habitats include Hawaiian monk seal critical habitat, 

21 four NWRs, two NMSs, one national park, and one wilderness area (DOC/NOAA and DOI 2006, 

22 Wilderness.net 2006). The Northwestern Hawaiian Islands Marine National Monument was 

23 established in June 2006. The monument encompasses the healthiest and most undisturbed coral reef 

24 ecosystem in the U.S. and contains many rare, threatened, and endangered species. Three new marine 

25 national monuments will be established in 2009 in the Pacific Islands: the Marianas Trench, Pacific 

26 Remote Islands, and Rose Atoll Marine National Monuments. Two territorially protected marine 

27 sanctuaries are located in CNMI (Appendix E, Table E-4). 

28 3.2.2.2 SAV and Macroalgae 

29 From Maine to Virginia, eelgrass (Zostera marina) is the dominant SAV species, and co-occurs with 

30 widgeon grass (Ruppia maritima). In North Carolina, Cuban shoalgrass (Haludule wrightii) and 

31 eelgrass are the dominant SAV species. No SAV occurs in South Carolina and Georgia. In Florida, 
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1 dominant species of SAV include Cuban shoalgrass, turtlegrass (Thalassia testudinum), manatee 

2 grass (Syringodium filiforme), and several species of Halophila (Stephan et al. 2000). Johnson’s 

3 seagrass is a threatened species found along the east coast of Florida, from central Biscayne Bay to 

4 Sebastian Inlet. Critical habitat for Johnson’s seagrass has been designated in the Indian River 

5 Lagoon and Biscayne Bay, FL (Appendix E, Table E-5). Macroalgae species on the Atlantic Coast 

6 include sea lettuce (Ulva lactuca) and rockweed (Fucus spp.). On the Atlantic coast, SAV loss was 

7 reported in 23 of the 62 estuaries surveyed in NOAA’s National Estuarine Eutrophication 

8 Assessment. Severe SAV loss is occurring in the main stem of the Chesapeake Bay, 

9 Tangier/Pocomoke Sounds (MD), Patuxent River (MD), Choptank River (MD), and Gardiners Bay 

10 (NY). No severe SAV loss was found in the South Atlantic (North Carolina to Florida) (Bricker et al.

11 1999). 

12 In the Gulf of Mexico, six common SAV species include Cuban shoalgrass, turtlegrass, manatee 

13 grass, widgeon grass, paddle grass (Halophila decipensi), and star grass (Halophila engelmannii) 

14 (GMP 2004). Macroalgae species include Sargassum (Sargassum fluitans), forked sea tumbleweed 

15 (Dictyota bartaryresii), and watercress alga (Halimeda opuntia) (NMS 2005). SAV loss was reported 

16 in 18 of the 38 estuaries surveyed in NOAA’s National Estuarine Eutrophication Assessment. Severe 

17 SAV loss is occurring in Lake Pontchartrain, LA and Galveston Bay, TX (Bricker et al. 1999). 

18 Common SAV species on the Pacific Coast include eelgrass, surfgrass (Phyllospadix serrulatus), and 

19 pickelweed (Salicornia virginica) (NOAA CSC 2001). Macroalgae species include giant kelp 

20 (Macrocystis pyrifera), golden rockweed (Silvetia compressa), bull kelp (Nereocystis leutkeana), 

21 rockweed (Fucus sp.), and sea lettuce (NMS 2005, OCNMS 2004). An invasive alga, Caulerpa 

22 taxifolia, has been found in California coastal waters. SAV loss was reported in 8 of the 39 estuaries 

23 surveyed in NOAA’s National Estuarine Eutrophication Assessment. Severe SAV loss is occurring 

24 in Morro Bay and San Francisco Bay, CA (Bricker et al. 1999). 

25 In the Pacific Islands, common SAV species include paddle grass, Hawaiian paddle grass (Halophila 

26 hawaiiana), Halophila minor, and Halophila ovalis (NOAA CSC 2001). Macroalgae species include 

27 Stypopodium flabelliforme, Halitheda opuntia, Caulerpa webbiana, and Padina australis (NMS 

28 2005). Seagrass beds provide important foraging grounds for green, olive ridley, and loggerhead sea 

29 turtles. Six invasive species of macroalgae occur in Hawaii: Acanthophora spicifera, Hypnea 

30 musciformis, Kappaphycus spp., Eucheuma denticulatum, Avrainvillea amadelpha, and Gracilaria 

31 salicornia. These species are spreading and competing with native marine flora and fauna (Puttock et 

32 al. undated). 
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1 3.2.2.3 Sea Turtles 

2 Six species of sea turtles have the potential to occur on the Atlantic Coast. Threatened species 

3 include the loggerhead (Caretta caretta), green, and olive ridley (Lepidochelys olivacea) sea turtles. 

4 Olive ridley sea turtle occurrences are rare but have been recorded in Puerto Rico, southern Florida, 

5 and the Grand Banks. Endangered species include Kemp’s ridley (Lepidochelys kempii), leatherback, 

6 and hawksbill sea turtles. Hawksbill sea turtles commonly occur in southern Florida, Puerto Rico, the 

7 Virgin Islands, and the northern Gulf of Mexico, and have also been documented as far north as 

8 Massachusetts. The Florida breeding population of green sea turtles is also listed as endangered 

9 (Appendix E, Table E-6). Critical habitat for the green sea turtle is designated in waters extending 

10 seaward 3 nautical miles from the mean high water line of the Culebra Islands in Puerto Rico (50 

11 CFR 226.208). Critical habitat for the hawksbill sea turtle is designated in waters extending seaward 

12 3 nautical miles from the mean high water line of Isla Mona and Monito Island, Puerto Rico (50 CFR 

13 226.209). Critical habitat for the leatherback is designated off Sandy Point on St. Croix Island in the 

14 Caribbean and around southwest Cape Point. 

15 Four species of sea turtles have the potential to occur on the Pacific Coast. Threatened species 

16 include the green, olive ridley, and loggerhead sea turtles. Endangered species include the 

17 leatherback sea turtle and the green sea turtle breeding population found on the Pacific coast of 

18 Mexico. The East Pacific green turtle, or “black turtle,” may be referred to as Chelonia mydas 

19 agassizii. No sea turtles nest on the Pacific Coast of the U.S.; the closest nesting beaches are in Baja 

20 California, Mexico. However, all five species have been recorded in U.S. waters and have been 

21 found stranded on the coast. Foraging and short-term inter-breeding residency has been recorded for 

22 green turtles in San Diego and leatherbacks in central and northern California. Green sea turtles 

23 occasionally occur in Alaska and have been found in southern Alaskan waters. Olive ridley sea 

24 turtles occurrences are rare in Oregon, Washington, and Alaska, but have been recorded (Hodge 

25 2001). Loggerheads in Alaska are a rare occurrence and leatherbacks have been found in the Bering 

26 Sea (Appendix E, Table E-6). 

27 Five species of sea turtles have the potential to occur in the Pacific Islands. Threatened species 

28 include the green, loggerhead, and olive ridley sea turtles. Endangered species include the 

29 leatherback and hawksbill sea turtles (Appendix E, Table E-6). 
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1 3.2.2.4 Fish and Shellfish 

2 Three species of endangered fish occur on the Atlantic Coast: the Atlantic salmon (Salmo salar), the 

3 shortnose sturgeon (Acipenser brevirostrum), and the smalltooth sawfish (Pristis pectinata)

4 (Appendix E, Table E-7). Atlantic salmon are a DPS located in the Gulf of Maine. Atlantic salmon in 

5 Maine outside of the range of the Gulf of Maine DPS have been proposed for listing as endangered. 

6 The shortnose sturgeon occurs throughout the Atlantic Coast and the smalltooth sawfish occurs from 

7 North Carolina to Florida. There is no critical habitat designated for these species on the Atlantic 

8 Coast, but critical habitat has been proposed for the Gulf of Maine Atlantic salmon DPS. Commercial 

9 and recreational fisheries are managed by the states; the New England, Mid-Atlantic, South Atlantic, 

10 and Caribbean Fishery Management Councils; and NMFS. Important commercial, recreational, 

11 and/or ecological species include sand lance (Ammodytes hexapterus), bay anchovy (Anchoa 

12 mitchilli), Atlantic croaker (Micropongonia undulatus), Atlantic menhaden (Brevoortia tyrannus), 

13 American shad (Alosa sapidissima), and striped bass (Morone saxatilis). Shellfish species include 

14 blue crab (Calinectes sapidus), Atlantic oyster (Crassostrea virginica), and hard clams (Mercenaria 

15 mercenaria) (CIMS 2006). 

16 In the Gulf of Mexico, Gulf sturgeon is threatened and the smalltooth sawfish is endangered 

17 (Appendix E, Table E-8). Critical habitat has been designated for Gulf sturgeon in the Pensacola Bay 

18 system, Santa Rosa Sound, Mississippi Sound/Pascagoula Bay system, Choctawhatchee Bay system, 

19 Apalachicola Bay system, and Suwanee Sound (USFWS 2003). Critical habitat has been proposed for 

20 smalltooth sawfish along the southwestern coast of Florida. Commercial and recreational fisheries in 

21 the Gulf of Mexico are managed by the states, the Gulf of Mexico Fishery Management Council, and 

22 NMFS. Important commercial, recreational, and/or ecological species include Gulf menhaden 

23 (Brevoortia patronis), red drum (Sciaenops ocellatus), striped mullet (Mugil cephalus), and anchovy. 

24 Shellfish species include blue crab, stone crab (Menippe mercenaria), and penaeid shrimp. 

25 Protected shellfish and fish species that occur throughout the West Coast (excluding Alaska) include 

26 coho salmon (threatened and endangered), chinook salmon (threatened and endangered), sockeye 

27 salmon (Oncorhynchus nerka) (threatened and endangered), chum salmon (Oncorhynchus keta)

28 (threatened), and steelhead (threatened, endangered, and candidate). The southern DPS of green 

29 sturgeon (Acipenser medirostris) is listed as threatened in California. Two endangered species that 

30 only occur in California are the white abalone (Haliostis sorenseni) and the tidewater goby. Critical 

31 habitat has been designated for the tidewater goby and includes 10 coastal stream segments in Orange 

32 and San Diego counties, California (Appendix E, Table E-9). Critical habitat includes the stream 
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1 channels and their associated wetlands, floodplains, and estuaries (65 FR 69693–69717). There are 

2 no threatened or endangered fish species in Alaska. 

3 On the Pacific coast, the Southern Oregon/Northern California Coasts coho ESU and the Oregon 

4 Coast coho ESU are threatened. The Central California Coast coho ESU is endangered. Critical 

5 habitat has been designated for each of these coho ESUs. Four ESUs of chinook salmon are 

6 threatened and have critical habitat: the California Coastal ESU, the Central Valley spring-run ESU, 

7 the Lower Columbia River ESU, and the Puget Sound ESU. The Sacramento River winter-run ESU 

8 of chinook salmon is endangered and critical habitat has been designated for this ESU. Two ESUs of 

9 chum salmon are threatened and have critical habitat: Hood Canal summer-run ESU and the 

10 Columbia River ESU. Three ESUs of steelhead are threatened and have critical habitat: the Northern 

11 California ESU, the Central California ESU, and the South-Central California Coast ESU. The 

12 Southern California ESU of steelhead is endangered and has designated critical habitat. Threatened 

13 chinook salmon ESUs that could be incidentally harvested in Alaska include the Snake River fall-run 

14 ESU, Upper Willamette River ESU, Puget Sound ESU, and the Lower Columbia River ESU (NMFS 

15 2005). 

16 Commercial and recreational fisheries on the West Coast are managed by the states, the Pacific 

17 Fishery Management Council, the North Pacific Fishery Management Council, and NMFS. 

18 Important commercial, recreational, ecological, and/or subsistence species include salmon, California 

19 halibut (Paralichthys californicus), white croaker (Genyonemus lineatus), Pacific herring (Clupea 

20 harengus pallasi), Atka mackerel (Pleurogrammus monopterygiusi) and Pacific cod (Gadus 

21 macrocephalus) (CDFG 2001, WDFW 1997, WDFW 2006). Important shellfish species include 

22 Dungeness crab (Cancer magister), Pacific razor clam (Siliqua patula), geoduck clam (Panopea 

23 abrupta), king crab (Paralithodes spp.), and Tanner crab (Chionoecetes bairdi) (ADFG 2006). 

24 No threatened or endangered species of fish occur in the Pacific Islands. Commercial and 

25 recreational fisheries are managed by the State of Hawaii, U.S. Territories, the Western Pacific 

26 Fishery Management Council, and NMFS. Important commercial, recreational, and/or ecological 

27 species include albacore tuna (Thunnus alalunga), skipjack tuna (Katsuwonus pelamis), wahoo 

28 (Acanthocybium solanchi), wrasses (Labridae), jacks (Carangidae), and blue marlin (Makaira 

29 nigricans) (NMFS 2005). 
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1 3.2.2.5 Coastal and Marine Birds 

2 Threatened species on the U.S. Atlantic Coast include the bald eagle (Haliaeetus leucocephalus) and 

3 piping plover. Critical habitat for wintering populations of piping plovers has been designated along 

4 the coastal shoreline of North Carolina and south along the eastern coast of the U.S. to the Gulf of 

5 Mexico. The wood stork (Mycteria americana) is endangered from South Carolina to Florida. The 

6 yellow-shouldered blackbird is listed as endangered only in Puerto Rico. Critical habitat for the 

7 yellow-shouldered blackbird has been designated on the main island of Puerto Rico and on Isla Mona. 

8 The roseate tern (Sterna dougallii dougallii) is endangered from Maine to North Carolina. The 

9 Caribbean population of the roseate tern is threatened in Florida, Puerto Rico, and the Virgin Islands. 

10 A non-essential population of whooping cranes is located from Virginia to Florida. Individuals of the 

11 population are treated as threatened if they occur in a NWR or national park. (Appendix E, Table E12 10). Seabirds, shorebirds, wading birds, and waterfowl using the Atlantic Flyway migrate through or 

13 nest on the Atlantic coast. Species include the great blue heron (Ardea herodius), snowy egret 

14 (Egretta thula), osprey (Pandion haliaetus), great cormorant (Phalacrocorax carbo), red knot 

15 (Calidris canutus), and whimbrel (Numenious phaeopus) (Clark and Niles 2000). 

16 Threatened species in the Gulf of Mexico include the bald eagle and piping plover. Piping plover 

17 critical habitat has been designated along the coastal shoreline of the Gulf Coast, from Texas to 

18 Florida. The whooping crane is only listed as endangered in Texas and critical habitat has been 

19 designated along the Texas Gulf Coast. The brown pelican (Pelecanus occidentalis) is endangered in 

20 Texas, Louisiana, and Mississippi. The wood stork is only endangered in Alabama (Appendix E, 

21 Table E-11). The Mississippi and Central Flyways pass through the Gulf of Mexico. Species that 

22 migrate through or nest on the coast include the snowy egret, great blue heron, gull-billed tern (Sterna 

23 nilotica), sanderling (Calidris alba), and American oystercatcher (Haematopus palliates) (Hunter et 

24 al. 2002, Elliott and McKnight 2000). 

25 Threatened species found from California to Alaska include the bald eagle, marbled murrelet, and the 

26 western snowy plover (Appendix E, Table E-12). Critical habitat for the western snowy plover has 

27 been designated in California, Oregon, and Washington. Critical habitat for the marbled murrelet has 

28 been designated in Alaska. Other threatened species found in California include the Coastal 

29 California gnatcatcher and the San Clemente sage sparrow (Amphispiza belli clementeae). Critical 

30 habitat for the Coastal California gnatcatcher has been designated in along the southern California 

31 coast. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-13 

1 Endangered species on the entire West Coast include the short-tailed albatross (Phoebastria albatrus) 

2 and Alaska breeding population of Steller’s eider (Appendix E, Table E-12). Occurrences of Steller’s 

3 eider in California, Oregon, and Washington are rare or accidental. Critical habitat for the Steller’s 

4 eider has been designated in Alaska. The endangered brown pelican is found in California, Oregon, 

5 and Washington. Endangered species only found in California include the California clapper rail 

6 (Rallus longirostris obsoletus), light-footed clapper rail (Rallus longirostris levipes), San Clemente 

7 loggerhead shrike (Lanius ludovicianus mearnsi), and California least tern (Sterna antillarum 

8 browni). The California condor (Gymnogyps californianus) is an endangered species that has 

9 recently been reintroduced in Southern California and may be found along the coast. In Alaska, the 

10 spectacled eider is endangered and critical habitat has been designated. 

11 The Pacific Flyway passes through the U.S. Pacific Coast. Species include the royal tern (Sterna 

12 maxima), common murre (Uria aalge), snowy egret, Caspian tern (Sterna caspia), black-crowned 

13 night heron (Nycticorax nycticorax), and the sooty shearwater (Puffinus griseus) (Hickey et al. 2003, 

14 USFWS 2005, ADFG 2005). 

15 Eleven endangered coastal and marine bird species are found in the Pacific Islands area: the short16 tailed albatross, Hawaiian coot (Fulica Americana alai), Hawaiian duck (Anas wyvilliana), laysan 

17 duck (Anas laysanensis), laysan finch (Telespyza cantans), nihoa finch (Telespyza ultima), Hawaiian 

18 dark-rumped petrel (Pterodroma phaeopygia sandwichensis), Newell’s Townsend’s shearwater 

19 (Puffinus auricularis newelli), Hawaiian stilt (Himantopus mexicanus knudseni), Guam bridled white20 eye (Zosterops conspicillatus conspicillatus), and Mariana crow (Corvus kubaryii) (Appendix E, 

21 Table E-13). No critical habitat has been designated for these bird species. 

22 A variety of birds inhabit the region including geese, ducks, coots, rails, waders, and gulls. Species 

23 include the Hawaiian goose (Branta sandvicensis), Tahiti petrel (Pterodroma rostrata), black24 crowned night-heron, pacific-golden plover (Pluvialis fulva), and red-footed booby (Sula sula) (HAS 

25 2002, USFWS 2005). 

26 3.2.2.6 Marine Mammals 

27 Most marine mammal species are wide-ranging and have been reported stranded in all NMFS regions. 

28 Populations of some species such as large whales, pinnipeds, and some small cetaceans routinely 

29 cross regional boundaries. Other marine mammals are considered resident, staying to a relatively 

30 localized area. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-14 

1 Animals that strand live may be immediately released, transferred to a rehabilitation facility, 

2 euthanized, or die naturally. Animals in rehabilitation may be released, sent to a public display or 

3 research facility (if deemed nonreleasable), euthanized, or they may die naturally. Significantly more 

4 pinnipeds strand each year than cetaceans. Figure 3-1 shows the total number of strandings (dead and 

5 live) nationwide from 2001-2006. The majority of stranded pinnipeds are alive when first reported, 

6 and up to 50 percent of the rehabilitated seals and sea lions are released back into the environment. 

7 The majority of cetaceans strand dead. Of the live-stranded small cetaceans, few are taken into a 

8 rehabilitation facility and very few are released. Only one mysticete has ever been rehabilitated in the 

9 U.S. – a juvenile gray whale (Eschrichtius robustus) in the Southwest Region. Figures 3-2 and 3-3 

10 summarize nationwide pinniped and cetacean strandings, respectively, from 2001-2006. Released 

11 animals are those that were taken into a rehabilitation facility and released after treatment. 

12 In this section, descriptions of the marine mammals that may occur in each NMFS region are 

13 presented, along with an overview of stranding information, including trends in strandings by 

14 numbers, species and seasonality, mass strandings, and UMEs. 

0

1000

2000

3000

4000

5000

6000

2001 2002 2003 2004 2005 2006

Year

Number of Strandings

Cetaceans

Pinnipeds

15 

16 Figure 3-1. Nationwide Stranding Summary 2001-2006 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-15 

0

1000

2000

3000

4000

5000

6000

2001 2002 2003 2004 2005 2006

Year

Number of Strandings

Released Pinnipeds

Live Pinnipeds

Dead Pinnipeds

1 

2 Figure 3-2. Pinniped Strandings Nationwide 2001-2006 

3 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-16 

0

200

400

600

800

1000

1200

1400

1600

1800

2001 2002 2003 2004 2005 2006

Year

Number of Strandings

Released Cetaceans

Live Cetaceans

Dead Cetaceans

1 

2 Figure 3-3. Cetacean Strandings Nationwide 2001-2006
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-17 

1 NMFS Northeast Region. Thirty-eight species of marine mammals have the potential to occur in the 

2 Northeast Region (Appendix E, Table E-14) (Geraci and Lounsbury 2005). Six of these species are 

3 listed as endangered: the North Atlantic right whale, humpback whale, fin whale, blue whale, sei 

4 whale, and sperm whale. All threatened and endangered marine mammal species are listed as 

5 depleted under the MMPA. The Western North Atlantic coastal migratory stock of bottlenose 

6 dolphins, which range from New Jersey to Florida, are also listed as depleted under the MMPA. 

7 Critical habitat for the right whale is designated within this region in portions of Cape Cod Bay, 

8 Stellwagen Bank, and the Great South Channel off the coast of Massachusetts (59 FR 28793-28834). 

9 The most commonly stranded pinniped species in the Northeast Region are harbor seals (Phoca 

10 vitulina), harp seals (Phoca groenlandica), hooded seals (Cystophora cristata), and gray seals 

11 (Halichoerys grypus). The number of stranded pinnipeds and particularly the ice seals (harp, hooded 

12 and gray seals) has been increasing in recent years. This is believed to be due to growth in the overall 

13 Northeast pinniped populations. Figure 3-4 depicts the number of reported pinniped strandings in the 

14 Northeast Region from 2001-2006. Twelve pinnipeds were placed in public display facilities from 

15 2001-2006. 

16 The most commonly stranded cetacean species in the Northeast Region are bottlenose dolphins, 

17 harbor porpoises (Phocoena phocoena), Atlantic white-sided dolphins (Lagenorhynchus acutus), 

18 common dolphins (Delphinus delphis), pilot whales (Globicephala melas and G. macrorhynchus), 

19 and minke whales. Other less common strandings include striped dolphins (Stenella coeruleoalba), 

20 Risso’s dolphins, pygmy sperm whales (Kogia breviceps), dwarf sperm whales (Kogia sima), sperm 

21 whales, killer whales, humpback whales, right whales, and fin whales. Many of the large whale 

22 carcasses are discovered floating many miles offshore by aerial survey and fishery spotter planes, and 

23 never land on the beach unless towed in by the stranding network for sampling. Figure 3-5 shows 

24 cetacean strandings in the Northeast Region from 2001-2006. Two cetaceans were placed in public 

25 display facilities from 2001-2006. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-18 

0

200

400

600

800

1000

1200

1400

2001 2002 2003 2004 2005 2006

Year

Number of Strandings

Released Pinnipeds

Live Pinnipeds

Dead Pinnipeds

1 

2 Figure 3-4. Northeast Region Pinniped Strandings 2001-2006 

0

100

200

300

400

500

2001 2002 2003 2004 2005 2006

Year

Number of Strandings

Released Cetaceans

Live Cetaceans

Dead Cetaceans

3 

4 Figure 3-5. Northeast Region Cetacean Strandings 2001-2006 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-19 

1 Mass Strandings. The Northeast Region, particularly Cape Cod, MA, has one of the highest 

2 incidences of live single and mass strandings of small cetaceans in the U.S. Mass strandings occur an 

3 average of once per year on Cape Cod and 6 to 10 live cetacean stranding events (single or mass 

4 strandings) occur annually in the Northeast Region, most often in the winter. Each event may involve 

5 single or multiple animals, resulting in the large proportion of live strandings in Figure 3-5. 

6 Human Interactions. Approximately 25 fisheries interactions are documented annually. Bottlenose 

7 dolphins and harbor porpoise are the small cetaceans most frequently impacted by human 

8 interactions, primarily fishery interactions. Large whales also show evidence of fishery and other 

9 human interactions. Approximately 61.6 percent of the overall right whale population shows physical 

10 evidence of entanglements (such as scars) and between 10 to 28 percent experience entanglement 

11 each year (Hamilton et al. 1998, Knowlton et al. 2001). According to the 2003 Stock Assessment, 60 

12 percent of right whale mortalities and serious injuries reported from 1997 to 2001 resulted from 

13 entanglements or fishery interactions (NMFS 2003). This number increased to approximately 69 

14 percent from 1999 to 2003 (NMFS 2005b). Disentanglement activity reports to the MMHSRP have 

15 verified entanglements of right, humpback, fin, and minke whales. Ship strikes of right whales have 

16 also been documented in the region. More than half (56 percent) of the recorded right whale ship 

17 strikes from 1975 to 2002 occurred off the coasts of the Northeast U.S. and Canada, and the mid18 Atlantic area accounted for 22 percent (Jensen and Silber 2003). Six confirmed ship strikes of Gulf 

19 of Maine humpback whales and eight confirmed ship strikes of Western North Atlantic fin whales 

20 occurred from 2001 to 2005 in the Northeast Region (Nelson et al. 2007). Ship strikes have also been 

21 documented for sperm, sei, blue, and minke whales (Jensen and Silber 2003). 

22 Temporal Changes. Stranding patterns vary temporally as marine mammal distribution changes with 

23 the seasons. In the spring, strandings of gray seal pups and harbor porpoise are common, as well as 

24 mass strandings of small cetaceans. Harbor seal pups, bottlenose dolphins, and large whale 

25 strandings are common in summer. Ship strikes and entanglements are frequent in summer. Fall 

26 strandings may include marine mammals in out of habitat situations. Common strandings in winter 

27 include juvenile ice seals, as they fail to forage successfully. Ice seal populations have also been 

28 increasing in Canada, leading to increasing numbers of animals in U.S. waters. 

29 Marine Mammal Population Changes. The North Atlantic right whale population continues to be 

30 depleted and has not shown any signs of recovery. The best estimate of the size of the North Atlantic 

31 right whale population is a range of 300 to 350. Although other population size estimates are 

32 available, the most recent Stock Assessment Report (Waring et al. 2007) indicates that the best 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-20 

1 estimate minimum population size for the species is 313 individually-recognized whales known to be 

2 alive in 2002. Recent models indicate that this population is likely declining, rather than remaining 

3 static or increasing (Caswell et al. 1999). Recent abundance estimates of the humpback whale Gulf 

4 of Maine stock indicated a continued increase in population growth. However, the size of the 

5 humpback whale stock may be below the Optimum Sustainable Population (OSP) in the U.S. EEZ. 

6 Populations of gray, harp, hooded, and harbor seals are likely increasing in the U.S. EEZ (Waring et 

7 al. 2007). 

8 UMEs. Table 3-1 describes the UMEs that have occurred in the Northeast Region from 1991 to April 

9 2008. The 2006-2007 pinniped UME was declared after morbillivirus was found in several pinnipeds 

10 in rehabilitation, and later detected from carcasses. Morbillivirus is the highly contagious and lethal 

11 genus of virus (Family Paramyxoviridae) that has been responsible for more significant marine 

12 mammal die-offs due to infectious disease than any other pathogen to date. These Morbillivirus die13 offs include several seal epizootics in Northern Europe and Russia involving tens of thousands of 

14 seals, and dolphin mortalities in the Mediterranean Sea and along the U.S. Atlantic and Gulf of 

15 Mexico coasts. In April 2008, a UME was declared in for offshore delphinids in the Mid-Atlantic. 

16 Table 3-1. UMEs in the Northeast Region, 1991-2008 

Year Species Location Cause Numbers of 

Animals 

1991 Harbor seals New York possible 

erysipelas 24 

1992 Phocids New 

England 

infectious 

disease 24 

2003 Large whales (primarily 

humpback whales) 

Gulf of 

Maine 

domoic acid 

(suspected) 21 

2003 Harbor seals and minke whales Maine undetermined 

(results pending) 

21 minke 

whales, 42 

harbor seals 

2004 Small cetaceans Virginia undetermined 67 

2005 Large whales North 

Atlantic undetermined ~34 

2006-

2007 Humpback whales North 

Atlantic 

undetermined, 

UME has not 

been closed 

48 

2006-

2007 Pinnipeds North 

Atlantic morbillivirus 

>1000 (harbor, 

gray, harp, and 

hooded seals) 

2008 

Offshore delphinids (primarily 

common and Atlantic whitesided dolphins) 

MidAtlantic undetermined 35 

Reference: NMFS 2008b 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-21 

1 

2 NMFS Southeast Region. Thirty-two species of marine mammals have been reported in the 

3 Southeast Region (Appendix E, Table E-15) (Geraci and Lounsbury 2005). Six of these species are 

4 listed as endangered: the West Indian manatee, North Atlantic right whale, humpback whale, blue 

5 whale, sei whale, and sperm whale. All threatened and endangered marine mammal species are also 

6 listed as depleted under the MMPA. The Western North Atlantic coastal migratory stock of 

7 bottlenose dolphins are also listed as depleted under the MMPA. Critical habitat for the right whale is 

8 designated from the shoreline between the mouth of the Altamaha River, Georgia, to the Sebastian 

9 River Inlet, Florida, seaward to 15 nautical miles (59 FR 28793-28834). Critical habitat for the West 

10 Indian manatee is designated within several watersheds along the east and west coast of Florida (42 

11 FR 47840–47845). 

12 The most commonly stranded pinniped species in the Southeast Region are harbor seals, representing 

13 over 90 percent of stranded pinnipeds. The majority (80 percent) of these strandings are immediately 

14 released back into the water. Other pinnipeds that strand in the Southeast Region include small 

15 numbers of hooded, harp, and gray seals. Recently there has been an increase in strandings of these 

16 seal species, many of them in the Caribbean. Figure 3-6 depicts the number of reported pinniped 

17 strandings in the Southeast Region from 2001-2004. Ten pinnipeds were placed in public display 

18 facilities from 2001-2006. 

19 The Southeast region currently has the most stranded cetaceans of any region, and a variety of taxa 

20 are represented (an average of 17 species of odontocetes annually). The most commonly stranded 

21 species in the Southeast region are bottlenose dolphins, pygmy sperm whales, dwarf sperm whales, 

22 and harbor porpoise. Other cetaceans that strand regularly, but in smaller numbers overall include: 

23 striped dolphins, spinner dolphins (Stenella longirostris), Atlantic spotted dolphins (Stenella 

24 frontalis), pantropical spotted dolphins (Stenella attenuata), Fraser’s dolphin (Lagenodelphis hosei), 

25 Risso’s dolphin, rough-toothed dolphin, melon-headed whales (Peponocephala electra), pilot whales, 

26 and several beaked whale species. Of mysticetes, the North Atlantic right whale is the most common 

27 mysticete to strand. On average, approximately three stranded right whales are reported each year in 

28 the Southeast Region. Other mysticetes that strand in the Southeast Region include humpback whales, 

29 minke whales, and rarely Bryde’s whales (Balaenoptera edeni) and sei whales. Figure 3-7 depicts the 

30 number of reported cetacean strandings in the Southeast Region from 2001-2006. Nineteen cetaceans 

31 were placed in public display facilities from 2001-2006. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-22 

0

5

10

15

20

25

2001 2002 2003 2004 2005 2006

Year

Number of Strandings

Released Pinnipeds

Live Pinnipeds

Dead Pinnipeds

1 

2 Figure 3-6. Southeast Region Pinniped Strandings 2001-2006

0

100

200

300

400

500

600

700

800

2001 2002 2003 2004 2005 2006

Year

Number of Strandings

Released Cetaceans

Live Cetaceans

Dead Cetaceans

3 

4 Figure 3-7. Southeast Region Cetacean Strandings 2001-2006 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-23 

1 Mass Strandings. Mass strandings occur frequently in the Southeast Region. The majority of mass 

2 strandings are either pilot whales or rough-toothed dolphins. Other species that have mass stranded 

3 include bottlenose dolphins, Fraser’s dolphins, striped dolphins, and pantropical spotted dolphins. 

4 Human Interactions. Human interactions accounted for 12 percent of the total number of strandings 

5 from 2001-2004. Of these, seven percent are fishery interactions including crab pot and recreational 

6 hook and line, and the remaining five percent of human-related mortality included boat strikes, gun 

7 shot wounds, and plastic ingestion. Documented human interactions with odontocetes are primarily 

8 fisheries interactions, although ship strikes do occur. Documented human interactions with 

9 mysticetes include entanglements and ship strikes. Reported right whale strandings have been 

10 associated with entanglements and boat strikes more often than other causes. Right whale 

11 entanglements are described above under the NMFS Northeast Region section. Three humpback 

12 whales, one fin whale, and one Bryde’s whale were confirmed entangled in the Southeast Region 

13 from 2001 to 2005 (Nelson et al. 2007). Twenty-two percent of the recorded right whale ship strikes 

14 from 1975 to 2002 occurred off the coast of the Southeast area (Jensen and Silber 2003). Two 

15 confirmed ship strikes of Gulf of Maine humpback whales have also occurred in the Southeast Region 

16 from 2001 to 2005 (Nelson et al. 2007). 

17 Temporal Changes. Seasonal peaks are seen in many species in the Southeast Region, and are 

18 generally related to migratory patterns, calving seasons, environmental conditions (including water 

19 temperature and harmful algal blooms) and fishery activities. For example, bottlenose dolphin 

20 strandings generally occur in the spring and summer in the more southern parts of the region, and in 

21 the spring and fall towards the north. Right whale and humpback whale strandings are most common 

22 in the southern component of their home range from November through April. 

23 Marine Mammal Population Changes. Population changes to North Atlantic right whales and Gulf of 

24 Maine humpbacks are the same as those listed for the Northeast Region. The West Indian manatee 

25 population trends are poorly known. However, based upon a carcass recovery program in Florida, 

26 manatee deaths have increased by an average of 5.9 percent per year from 1976 through 1992. 

27 UMEs. Table 3-2 describes the UMEs that have occurred in the Southeast Region as from 1991 to 

28 April 2008. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-24 

1 Table 3-2. UMEs in the Southeast Region, 1991-2008 

Year Species Location Cause Numbers of 

Animals 

1991 Bottlenose 

dolphins Florida (Sarasota) undetermined 30 

1992 Bottlenose 

dolphins Texas undetermined 220 

1994 Bottlenose 

dolphins Texas morbillivirus 72 

1996 Right whales Florida, Georgia human interaction 6 

1996 Manatees Florida (West 

Coast) brevetoxin 149 

1996 Bottlenose 

dolphins Mississippi undetermined 30 

1999-2000 Bottlenose 

dolphins 

Florida 

(Panhandle) brevetoxin 115 

2001 Bottlenose 

dolphins 

Florida (Indian 

River) 

undetermined 

(saxitoxin 

suspected) 

35 

2002 Manatees Florida (West 

Coast) brevetoxin 34 

2003 Manatees Florida (West 

Coast) 

brevetoxin 

(suspected) 96 

2004 Bottlenose 

dolphins 

Florida 

(Panhandle) 

undetermined 

(brevetoxin 

suspected) 

107 

2004 Small cetaceans North Carolina undetermined 100 

2005-2006 

Multispecies 

(manatees, 

bottlenose 

dolphins) 

Florida (West 

Coast) 

brevetoxin 

(suspected) 

204 bottlenose 

dolphins, 130 

manatees 

2005 Harbor porpoises North Carolina undetermined 43 

2005-2006 Bottlenose 

dolphins 

Florida 

(Panhandle) 

brevetoxin 

(suspected) 97 

2006 Manatees Florida 

(Everglades) 

brevetoxin 

(suspected) 24 

2007 Bottlenose 

dolphins 

Texas and 

Louisiana undetermined 62 

2007 Manatees Florida (west 

coast) brevetoxin 37 

2008 

Bottlenose 

dolphins (majority 

are neonates) 

Texas undetermined ~120 

2008 Bottlenose 

dolphins 

Florida (Indian 

River) undetermined ~48 

Reference: NMFS 2008b 

2 

3 NMFS Southwest Region. Thirty-seven species of marine mammals have the potential to occur in 

4 the Southwest Region (Appendix E, Table E-16) (Geraci and Lounsbury 2005). The Steller sea lion, 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-25 

1 southern sea otter (Enhydra lutris nereis), and Guadalupe fur seal are listed as threatened. 

2 Humpback, blue, sei, sperm, fin, and North Pacific right whales are listed as endangered. All 

3 threatened and endangered marine mammal species are listed as depleted under the MMPA. In 

4 California, Steller sea lion critical habitat is designated as major rookeries and their associated air and 

5 aquatic zones. The air zones extend 3,000 feet above rookery areas historically occupied by sea lions, 

6 and aquatic zones extend 3,000 feet seaward from these areas (58 FR 45269–45285). 

7 The most commonly stranded pinniped species in the Southwest region are California sea lions 

8 (Zalophus californianus), followed by harbor seals and northern elephant seals (Mirounga 

9 angustirostris). There are also infrequent strandings of Steller sea lions, Guadalupe fur seals, and 

10 northern fur seals. Over half of all stranded otariids were reported alive when first observed. Figure 

11 3-8 depicts the number of reported pinniped strandings in the Southwest Region from 2001-2006. 

12 Eighteen pinnipeds were placed in public display facilities from 2001-2006. 

13 The most commonly stranded small cetaceans in the Southwest Region are long- and short-beaked 

14 common dolphins (Delphinus capensis and D. delphis), harbor porpoise, bottlenose dolphins, Risso’s 

15 dolphins, Dall’s porpoises (Phocenoides dalli), and Pacific white-sided dolphins (Lagenorhynchus 

16 obliquidens). The most commonly stranded large whales are gray whales, which in some years are 

17 the most commonly observed stranded cetacean. Infrequently stranded cetacean species include 

18 Northern right whale dolphins (Lissodelphis borealis), rough-toothed dolphins, pygmy and dwarf 

19 sperm whales, sperm whales, short-finned pilot whales, beaked whales, humpback whales, and minke 

20 whales (Balaenoptera acutorostrata). Most stranded cetaceans are dead when first observed and 

21 reported. Figure 3-9 depicts the number of reported cetacean strandings in the Southwest Region 

22 from 2001-2006. Two cetaceans were placed in public display facilities from 2001-2006. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-26 

0

500

1000

1500

2000

2500

3000

3500

4000

4500

5000

2001 2002 2003 2004 2005 2006

Year

Number of Strandings

Released Pinnipeds

Live Pinnipeds

Dead Pinnipeds

1 

2 Figure 3-8. Southwest Region Pinniped Strandings 2001-2006 

0

50

100

150

200

250

2001 2002 2003 2004 2005 2006

Year

Number of Strandings

Released Cetaceans

Live Cetaceans

Dead Cetaceans

3 

4 Figure 3-9. Southwest Region Cetacean Strandings 2001-2006 

5 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-27 

1 Mass Strandings. Mass strandings are rarely reported in the Southwest Region. 

2 Human Interactions. Documented human interactions in the Southwest region include boat strikes, 

3 fishery interactions, and deliberate shootings. Seventeen whales (10 gray whales and 7 humpback 

4 whales) were reported entangled in fishing gear, and other animals were determined to have been hit 

5 by ships. Each year some pinnipeds are documented to have been shot. 

6 Temporal Changes. The majority of gray whale strandings in the Southwest Region occur from 

7 March through May when the whales are found off the coast of California during their northern 

8 migration. Several large stranding events, affecting both odontocetes and pinnipeds, have been 

9 recorded in the spring coincident with the occurrence of large toxic phytoplankton blooms. Most 

10 elephant seal strandings are pups and most occur from March-May during the fasting period between 

11 the end of weaning and when the animals enter the open ocean to feed on their own. Most harbor seal 

12 strandings occur from April-June, coinciding with the peak of pupping season. 

13 Marine Mammal Population Changes. Most marine mammal stocks in California waters are stable 

14 and/or increasing. California sea lions have been increasing recently at 5.4 percent to 6.1 percent per 

15 year. Short-finned pilot whales have declined in abundance in the Southern California Bight. This 

16 decline is likely a result of a change in distribution since the 1982-1983 El Niño event. The 

17 Guadalupe fur seal population has been growing at approximately 13.7 percent per year (Carretta et 

18 al. 2007). 

19 UMEs. Table 3-3 describes the UMEs that have occurred in the Southwest Region from 1991 to 

20 April 2008. 

21 Table 3-3. UMEs in the Southwest Region, 1991-2008 

Year Species Location Cause Number of 

Animals 

1991 California sea lions California leptospirosis 160 

1992-

1993 Pinnipeds California El Nino ~1000 

1994 Common dolphins California undetermined 53 

1997 Harbor seals California viral 

pneumonia 90 

1998 California sea lions California domoic acid 70 

1999-

2001 Gray whales California, Oregon, 

Washington undetermined 651 

2000 California sea lions California domoic acid 184 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-28 

Table 3-3. UMEs in the Southwest Region, 1991-2008 (continued) 

Year Species Location Cause Number of 

Animals 

2000 Harbor seals California infectious 

disease 26 

2002 

Multispecies (common 

dolphins, California sea 

lion, sea otters) 

California domoic acid ~500 

2003 Sea otters California ecological 

factors 69 

2007 Cetaceans (primarily 

common dolphins) California domoic acid 63 

2007 Large whales (primarily 

blue whales) California 

human 

interaction, 

undetermined 

8 

Reference: NMFS 2008b 

1 

2 NMFS Northwest Region. Twenty-eight species of marine mammals have the potential to occur in 

3 the Northwest Region (Appendix E, Table E-17) (Geraci and Lounsbury 2005). The Steller sea lion 

4 is the only threatened marine mammal species in the region. Endangered marine mammal species 

5 include the humpback, blue, sei, sperm, fin, and North Pacific right whales. The Southern Resident 

6 DPS of killer whales in Washington is also listed as endangered. Approximately 2,560 square miles 

7 of inland waters of Washington have been designated as critical habitat for the Southern Resident 

8 killer whale DPS (71 FR 69054-69070). All threatened and endangered species are listed as depleted 

9 under the MMPA. The Eastern Pacific stock of the northern fur seal (Callorhinus ursinus) is also 

10 listed as depleted under the MMPA. In Oregon, Stellar sea lion critical habitat is designated as major 

11 rookeries and their associated air and aquatic zones. The air zones extend 3,000 feet (0.9 kilometers) 

12 above rookery areas historically occupied by sea lions, and aquatic zones extend 3,000 feet seaward 

13 from these areas (58 FR 45269–45285). 

14 The majority of stranded animals in the region are harbor seals. Approximately 50 percent of 

15 stranded harbor seals are live when first observed and are predominantly pups. Other commonly 

16 stranded pinnipeds include California sea lions, Steller sea lions, and Northern fur seals. These 

17 animals are usually dead when first reported. The number of elephant seals reported to the network 

18 has recently been increasing, associated with recently colonized haul-out and breeding sites in 

19 southern Oregon and the inland waters of Washington. The majority of elephant seals that are 

20 reported to the network are not stranded, but are hauled out to molt. The network’s response includes 

21 posting signs to alert the public about the life history of the seals and to help prevent harassment of 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-29 

1 the resting animals. Figure 3-10 depicts the number of reported pinniped strandings in the Northwest 

2 Region from 2001-2006. The increasing trend in reported strandings, shown in Figure 3-10, may 

3 reflect improved coverage by the stranding network combined with increased funding. One pinniped 

4 was placed in a public display facility from 2001-2006. 

5 The most common stranded cetacean species are the gray whale, harbor porpoises, Dall’s porpoises, 

6 Pacific white-sided dolphins, killer whales, sperm whales, Risso’s dolphin, minke, humpback, and fin 

7 whales. Seventeen different odontocete species, including beaked whales, have been reported 

8 stranded from 1989-2003. The majority of stranded odontocetes are dead when first observed. 

9 Figure 3-11 depicts the number of reported cetacean strandings in the Northwest Region from 2001-

10 2006. The increasing trend in reported strandings, shown in Figure 3-11, may reflect improved 

11 coverage by the stranding network combined with increased funding. No cetaceans were placed in 

12 public display facilities from 2001-2006. 

0

100

200

300

400

500

600

700

2001 2002 2003 2004 2005 2006

Year

Number of Strandings

Released Pinnipeds

Live Pinnipeds

Dead Pinnipeds

13 

14 Figure 3-10. Northwest Region Pinniped Strandings 2001-2006 

15 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-30 

0

20

40

60

80

100

120

2001 2002 2003 2004 2005 2006

Year

Number of Strandings

Released Cetaceans

Live Cetaceans

Dead Cetaceans

1 

2 Figure 3-11. Northwest Region Cetacean Strandings 2001-2006 

3 Mass Strandings. The occurrence of mass strandings in Oregon and Washington is rare. However, a 

4 mass stranding of 41 sperm whales occurred in central Oregon in 1979. 

5 Human interactions. Boat strikes and fisheries interactions with large whales have been documented. 

6 Documented human interactions with phocids include fisheries interactions, vehicle collisions, and 

7 shootings. Documented human interactions involving otariids are primarily shootings. 

8 Temporal changes. Gray whales strand most frequently in the spring during their northward 

9 migration. 

10 Marine Mammal Population Changes. The Southern Resident killer whale DPS experienced an 

11 almost 20 percent decline from 1996 to 2001. Since 2001 there has been a small increase in the 

12 population, and there were 87 whales in the Southern Resident DPS in 2007 (NMFS 2008a). Based 

13 on aerial surveys, the Washington inland stock of harbor porpoise has increased three fold since 1997. 

14 The outer coast stock of harbor porpoise appears to be declining. There has also been an increase in 

15 male California sea lions in Washington State waters. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-31 

1 UMEs. Table 3-4 describes the UMEs that have occurred in the Northwest Region from 1991 to 

2 April 2008. 

3 Table 3-4. UMEs in the Northwest Region, 1991-2008 

Year Species Location Cause Numbers of 

Animals 

1993 Pinnipeds Washington human 

interaction 53 

1999-

2001 Gray whales California, Oregon, 

Washington undetermined 651 

2006 Harbor porpoises Oregon, Washington undetermined 113 

2007 Guadalupe fur 

seals Oregon, Washington undetermined 15 

Reference: NMFS 2008b 

4 

5 NMFS Alaska Region. Twenty-nine species of marine mammals have the potential to occur in the 

6 Alaska Region (Appendix E, Table E-18) (Geraci and Lounsbury 2005). Threatened marine mammal 

7 species include the southwest Alaska DPS of the northern sea otter (Enhydra lutris kenyoni), the 

8 eastern DPS of the Steller sea lion, and the polar bear. Endangered marine mammal species include 

9 the western DPS of Steller sea lions, the Cook Inlet stock of beluga whales (Delphinapterus leucas), 

10 bowhead (Balaena mysticetus), blue, humpback, fin, sei, sperm, and North Pacific right whales. 

11 ESA Candidate species include bearded, ringed, and spotted seals. All threatened and endangered 

12 species are listed as depleted under the MMPA. The Eastern Pacific Stock of northern fur seals is 

13 listed as depleted under the MMPA. The AT1 group of transient killer whales is also listed as 

14 depleted. Critical habitat for the Steller sea lion is designated within Alaska and is defined as major 

15 rookeries; haul-outs; and associated terrestrial, air, and aquatic zones. There are also three special 

16 aquatic foraging areas that are designated as critical habitat for the Steller sea lion: Shelikof Strait (in 

17 the Gulf of Alaska), Bogoslof Island area and Seguam Pass (in the Bering Strait), and the Aleutian 

18 Islands area (58 FR 45269–45285). Critical habitat for the North Pacific right whale has been 

19 designated in the Gulf of Alaska and the Southeast Bering Sea (71 FR 38277-38297). 

20 The Alaska Regional Stranding Network coordinates with Alaska Native tribal governments and 

21 villages, particularly for species that have co-management agreements, as mandated through Section 

22 119 of the MMPA. Stranded animals are examined to determine if the death resulted from a struck23 but-lost situation. At times, Native villages request parts from an animal for subsistence use or 

24 Native articles of handicrafts and clothing. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-32 

1 Stranding reports in Alaska are limited by the extensive and mostly rural coastline. Commonly 

2 reported stranded pinniped species (excluding walrus) include harbor seal, Steller sea lion, ringed 

3 seal, bearded seal, spotted seal, and elephant seal. On average, from 2001-2006, five harbor seal pups 

4 a year were brought to the rehabilitation facility in Alaska. Figure 3-12 depicts the number of 

5 reported pinniped strandings (excluding walrus) in the Alaska Region during from 2001-2006. One 

6 pinniped was placed in a public display facility from 2001-2006. 

7 The most commonly stranded cetacean species in the Alaska Region are gray whales, beluga whales, 

8 humpback whales, killer whales, Dall’s porpoise, harbor porpoise, and Cuvier’s (Ziphius cavirostris), 

9 Baird’s (Berardius bairdii), and Stejneger’s (Mesoplodon stejnegeri) beaked whales. Infrequently 

10 reported stranded species include Pacific white-sided dolphins, sperm whales, minke whales, and fin 

11 whales. Most beluga whale strandings are from the Cook Inlet stock. On average, from 2001-2006, 

12 three beaked whale strandings were reported each year. Figure 3-13 depicts the number of reported 

13 cetacean strandings in the Alaska Region from 2001-2006. No cetaceans were released from 

14 rehabilitation during this time period. No cetaceans were placed in public display facilities from 

15 2001-2006. 

0

20

40

60

80

100

120

140

2001 2002 2003 2004 2005 2006

Year

Number of Strandings

Released Pinnipeds

Live Pinnipeds

Dead Pinnipeds

16 

17 Figure 3-12. Alaska Region Pinniped Strandings 2001-2006 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-33 

0

20

40

60

80

100

120

140

160

180

2001 2002 2003 2004 2005 2006

Year

Number of Strandings

Live Cetaceans

Dead Cetaceans

1 

2 

3 Figure 3-13. Alaska Region Cetacean Strandings 2001-2006 

4 

5 Mass Strandings. Cook Inlet beluga mass strandings, as related to tides, were reported three times in 

6 2000 (two unconfirmed reports) and five times in 2003 (two unconfirmed reports), with a best 

7 estimate of 20 animals per event. In 2006 there were six polar bear mortalities. Mass walrus 

8 mortalities are occasionally reported at Alaska terrestrial haul-outs. In 2005, about 30 walruses died 

9 from terrain falls at Cape Pierce in the Togiak National Wildlife Refuge. Trampling deaths have been 

10 reported in the Punuk Islands near St. Lawrence Island. 

11 Human Interactions. Documented human interactions for stranded animals include boat strikes and 

12 fisheries interactions. From 2000-2004, an average of seven humpback whale entanglements were 

13 reported annually. This number increased to approximately 22 in 2005 and 15 in 2006. Some of 

14 these entanglement events may be the result of increased reporting awareness or re-sightings of the 

15 same animal. However, the number of entangled humpback whale reports appears to be increasing. 

16 During this time, several bowhead and gray whales were also reported entangled. Several boat strike 

17 reports involving humpback whales are reported annually. Numerous cases of Steller sea lion fishery 

18 interactions are reported annually. These cases include animals that have swallowed hooks, flashers, 

19 and lures; animals with packing bands around their necks; and animals wrapped in net or other fishery 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-34 

1 related material. From 1996-2000, the estimated mean mortality of walruses from fisheries activities 

2 was 1.2 walrus per year. 

3 Temporal Changes. Most stranding reports of NMFS marine mammal species are received during the 

4 warmer months (May-October). No reported strandings of NMFS species appear to be from temporal 

5 or ice changes. Polar bear and Pacific walrus strandings would be most likely attributed to changing 

6 sea ice habitat and could occur year round. The most critical times for polar bears would likely be in 

7 the spring, soon after cubs are born, through the fall. For Pacific walrus, the critical time for young 

8 animals and calves would be during the late spring-early summer when the female and calves follow 

9 the ice pack north. 

10 Marine Mammal Population Changes. Some marine mammal populations are increasing, including: 

11 the Central North Pacific stock of humpback whales, bowhead whales, the eastern population stock of 

12 Steller sea lions, and Bristol Bay beluga whales. Harbor seal populations have experienced declines 

13 in parts of Alaska, notably the Aleutian Islands, Prince William Sound, and Glacier Bay. Cook Inlet 

14 belugas were designated as depleted on May 31, 2000 (65 FR 34590) and endangered on October 22, 

15 2008 (73 FR 62919). Surveys on Cook Inlet belugas from 1999-2008 have demonstrated a decline of 

16 1.5 percent per year (NMFS 2008c). AT1 killer whales were designated as depleted on June 3, 2004 

17 (69 FR 31321). Northern fur seals, which were designated as depleted on May 18, 1988 (53 FR 

18 17888) are not recovering and continue to decline. The size and trend of the Pacific walrus 

19 population are currently unknown. Population point estimates from 1975-1990 ranged between 

20 202,039 to 246,360 walruses, but were not precise enough to accurately reflect trend. The Southern 

21 Beaufort Sea population and Chukchi/Bering Seas populations of polar bear are thought to be 

22 declining. 

23 UMEs. A northern sea otter UME was declared in Alaska on August 24, 2006 for elevated levels of 

24 sea otter mortality since 2002, with the majority of deaths in 2005 and 2006. A significant and 

25 unusual pathology, Streptococcus bovis endocarditis/septicemia was reported in approximately 43 

26 percent of these animals. 

27 NMFS Pacific Islands Region. Twenty-three marine mammal species have the potential to occur in 

28 the Pacific Islands Region (Appendix E, Table E-19) (Geraci and Lounsbury 2005). No threatened 

29 species occur in the region. Endangered species include the Hawaiian monk seal and humpback, 

30 sperm, and fin whales. All endangered species are listed as depleted under the MMPA. Critical 

31 habitat for the Hawaiian monk seal is designated and is defined as all beach areas, sand spits, and 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-35 

1 islets (including all beach crest vegetation to its deepest extent inland), lagoon waters, and inner reef 

2 waters. Critical habitat also includes ocean waters out to a depth of 20 fathoms around Kure Atoll, 

3 Midway Islands (except Sand Island and its harbor), Pearl and Hermes Reefs, Lisianski Island, 

4 Laysan Island, Maro Reef, Gardner Pinnacles, French Frigate Shoals, Necker Island, and Nihoa 

5 Island (53 FR 18998). 

6 The only pinniped species to naturally occur in the Hawaiian Islands is the Hawaiian monk seal. 

7 Hawaiian monk seals rest and pup on beaches in the main Hawaiian Islands, and may mistakenly be 

8 reported as being stranded. However, a total of 10 sick and injured (stranded) monk seals were 

9 reported from 2000-2004, and 8 of these animals were found dead. Rarely, elephant seals may also 

10 be found stranded in the main Hawaiian Islands. Figure 3-14 depicts the number of reported pinniped 

11 strandings in the Pacific Islands Region from 2001-2006. No pinnipeds were sent to public display 

12 facilities during this period. 

13 The most common cetacean species to be reported stranded are humpback whales, sperm whales, 

14 spinner dolphins, spotted dolphins, and striped dolphins. Infrequently reported cetacean species 

15 include bottlenose dolphin, rough-toothed dolphin, pygmy sperm whale, dwarf sperm whales, pilot 

16 whales, false killer whales (Pseudorca crassidens), melon-headed whales, beaked whales, and killer 

17 whales. Approximately four large whales are reported stranded each year, with most of the strandings 

18 occurring during the humpback whale mating and calving season (November to April). Figure 3-15 

19 depicts the number of reported cetacean strandings in the Pacific Islands Region from 2001-2006. No 

20 cetaceans were sent to public display facilities during this period. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-36 

0

5

10

15

20

25

30

35

40

2001 2002 2003 2004 2005 2006

Year

Number of Strandings

Released Pinnipeds

Live Pinnipeds

Dead Pinnipeds

1 

2 Figure 3-14. Pacific Islands Region Pinniped Strandings 2001-2006 

3 

0

5

10

15

20

25

30

35

40

45

2001 2002 2003 2004 2005 2006

Year

Number of Strandings

Live Cetaceans

Dead Cetaceans

4 

5 

6 Figure 3-15. Pacific Islands Region Cetacean Strandings 2001-2006 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-37 

1 Mass Strandings. Mass strandings are rarely recorded in the Pacific Islands Region. However, in 

2 2004 a group of 150-200 melon-headed whales were reported close to shore inside Hanalei Bay on 

3 the island of Kaua‘i. These animals milled in shallow water for several hours and only returned to 

4 deep water after human intervention. The local citizens constructed a lau (a floating strand of woven 

5 vines) and used it to herd the animals out of the Bay. 

6 Human Interaction. On average, four monk seals are reported hooked or entangled in fishing gear or 

7 marine debris. Documented human interactions with large whales include boat strikes and fisheries 

8 interactions. Humpback whales have been reported entangled in fishing gear, with an average of four 

9 entanglements per year. 

10 Temporal Changes. No temporal changes have been noted in the Pacific Islands Region. 

11 Marine Mammal Population Changes. The Hawaiian monk seal population has been declining at an 

12 average of 3.8 percent per year since 1998. The population is well below historical levels and has not 

13 recovered from past declines. Since 2000, there has been a general decline in both abundance and 

14 juvenile survival at Pearl and Hermes Reef, Midway Atoll, and Kure Atoll. The main Hawaiian 

15 Islands population may be increasing, but this has not been confirmed and the abundance appears to 

16 be too low to influence the current total population numbers (Carretta et al. 2007). 

17 UMEs. A monk seal UME occurred from 2001 to 2002 due to starvation (NMFS 2008b). 

18 3.3 Water and Sediment Quality 

19 3.3.1 Definition of the Resource 

20 Water quality is defined as the biological, chemical, and physical properties of a waterbody that 

21 determine it’s suitability for human use or for its role in the ecosystem. In coastal environments 

22 water quality is influenced by river drainage, erosion, and atmospheric deposition (e.g., precipitation 

23 and dust). Human activities affect water quality through nonpoint source runoff, pollutant discharges, 

24 dumping, hazardous material spills, and air emissions. Water quality is determine through a variety 

25 of indicators, including dissolved inorganic nitrogen (DIN), dissolved inorganic phosphorus (DIP), 

26 water clarity, and dissolved oxygen. Concentrations of DIN and DIP that indicate poor condition 

27 vary according to location. Water clarity is considered poor if less than 10 percent of surface light 

28 reaches 1 m. Dissolved oxygen is considered poor if concentrations less than 2 mg/L are present. 

29 Data on water quality are mainly taken from the Environmental Protection Agency (EPA) National 

30 Coastal Condition Report II (NCCR) (EPA 2005). 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-38 

1 Sediment quality is the ability of sediment to support a healthy benthic population and it helps to 

2 determine the ecological health of aquatic systems. Sediments provide essential habitat and food for 

3 many organisms. Activities affecting sediment quality are runoff, pollutant discharges, dumping, 

4 hazardous materials spills, and air emissions. Typical sediment contaminants include heavy metals 

5 and POPs. POPs include dioxin, Polychlorinated Biphenyls (PCBs), Polycyclic Aromatic 

6 Hydrocarbons (PAHs), and pesticides. Most major harbors in the U.S. have moderate to severe 

7 sediment contamination. Sediment toxicity can be measured by conducting static toxicity tests with 

8 amphipods. Sediment contamination can be determined using Effects Range Median (ERM) and 

9 Effects Range Low (ERL) guidelines. The ERM is the median concentration of a contaminant 

observed to have adverse biological effects. The ERL is the 10th 10 percentile concentration of a 

11 contaminant demonstrating adverse biological effects. Sediment toxicity from organic matter can be 

12 assessed by measuring the Total Organic Carbon (TOC) content. Data on sediment quality are 

13 compiled in the NCCR (EPA 2005). 

14 3.3.2 Affected Environment 

15 The North Atlantic coast is the most densely populated coastal region in the U.S. The overall 

16 estuarine ecological condition is rated as poor. Twenty-seven percent of the estuarine area is 

17 impaired for aquatic life use. Thirty-one percent of the estuarine area is impaired for human use. The 

18 water quality in estuaries is considered fair to poor. The DIN rating is fair, with 11 percent having 

19 concentrations exceeding 0.5 mg/L. The DIP rating is good, with 5 percent having concentrations 

20 exceeding 0.05 mg/L. The overall rating of water clarity is fair, with 23 percent of the estuarine area 

21 in poor condition. Northeast estuaries dissolved oxygen concentrations are good. Hypoxia and 

22 anoxia were apparent in 10 percent of the estuarine area, mainly in the isolated trenches of the 

23 Chesapeake Bay (EPA 2005). 

24 A poor sediment quality rating was given to 16 percent of estuaries on the Northeast coast 

25 Unimpaired sediments are located in the Acadian Province (with the exception of Great Bay, NH), 

26 eastern Long Island Sound, and open regions of the Delaware and Chesapeake Bays. Toxic 

27 sediments were found in eight percent of Northeast estuaries. Sediments in Cape Cod Bay, New 

28 York Harbor, and western Long Island Sound are impaired by toxicity. Sediment contamination is 

29 considered fair. Sediment around major urban areas (New York Harbor, Narragansett Bay) exceeds 

30 ERM guidelines for metals and other organic contaminants. Other contaminants exceeding ERL 

31 guidelines included nickel, mercury, arsenic, chromium, Dichloro-Diphenyl-Trichloroethane (DDT), 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-39 

1 and PCBs. The TOC for estuaries was good and elevated TOC levels corresponded to areas with high 

2 sediment contamination (EPA 2005). 

3 Water quality of the South Atlantic coast estuaries is affected by the increasing coastal population. 

4 Estuarine areas are in fair to good ecological condition. Twenty-three percent of the estuarine area is 

5 impaired for aquatic life and human uses. The water quality in estuaries is considered fair to good. 

6 The DIN rating is good and no estuarine areas have a DIN concentration exceeding 0.5 mg/L. DIP is 

7 considered fair, with 12 percent having concentrations exceeding 0.05 mg/L. The overall rating of 

8 water clarity is fair, with 12 percent of the estuarine area in poor condition. Dissolved oxygen 

9 concentrations are good, with only two percent of the area exhibiting hypoxia. Sediment quality in 

10 the South Atlantic coast estuaries is fair to good. Sediment toxicity, contamination, and TOC are all 

11 considered good (EPA 2005). 

12 In Puerto Rico, the overall ecological condition of estuaries is poor. Seventy-seven percent of the 

13 area is impaired for aquatic life use. The water quality in estuaries is considered fair. DIN is 

14 considered good, with no estuaries exceeding concentrations greater than 0.1 mg/L. The DIP rating is 

15 good, with only six percent exceeding concentrations greater than 0.01 mg/L. Water clarity is fair 

16 and dissolved oxygen concentrations are good, with one percent of the areas exhibiting hypoxia. 

17 Water quality in all of Puerto Rico’s shoreline waters has been assessed. Twenty-one percent of 

18 shoreline waters are impaired, 24 percent are threatened, and 55 percent are fully supporting 

19 designated uses. Sediment quality is poor in Puerto Rico, with three percent of sediment considered 

20 toxic. Sediment contamination criteria (ERM and ERL) were exceeded in 23 percent of sediments, 

21 mostly for heavy metals, pesticides, and PCBs. Sediment TOC is poor, as 44 percent of sediment had 

22 a high TOC level (EPA 2002). 

23 The U.S. Virgin Islands surface water quality is generally good, but quality is declining due to an 

24 increase in point and non-point source discharges into the marine environment. Vessel wastes and 

25 uncontrolled runoff are major direct discharges into surface waters (VI DPNR 2001). Estuaries in the 

26 Virgin Islands have not been assessed, as these waterbodies are not considered to be true estuaries. 

27 Ninety-seven percent of the shoreline has been assessed. Four percent of shoreline waters are 

28 impaired, 10 percent threatened, and 86 percent are fully supporting designated uses (EPA 2005). 

29 Sediment quality information for the Virgin Islands is not available. 

30 Water quality in the Gulf of Mexico is affected by the growing population along the coast. The Gulf 

31 of Mexico estuarine area is in fair ecological condition. Thirty-five percent of the area is impaired for 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-40 

1 aquatic life uses, and 14 percent are impaired for human use. The water quality in estuaries is 

2 considered fair. DIN is considered good, with only two percent having concentrations greater than 

3 0.5 mg/L. The DIP rating is fair, with 11 percent having concentrations exceeding 0.05 mg/L. The 

4 overall rating of water clarity is fair, with 29 percent in poor condition. Dissolved oxygen 

5 concentrations are good, with only one percent of the area exhibiting hypoxia. Coastal and deeper 

6 waters of the Gulf are degraded from spills and dumping from vessels. An area of hypoxia, located 

7 off of the Louisiana continental shelf, begins in late spring and disappears in the fall. Sediment 

8 quality in the Gulf of Mexico is fair, with less than one percent exhibiting toxicity. However, the 

9 toxicity percentage may be different, as data was missing from 38 percent of estuaries. Sediment 

10 ERM guidelines were exceeded primarily in Texas estuaries and ERL guidelines were exceeded in 

11 Mobile Bay, AL. Sediment TOC levels are considered good in the Gulf Coast (EPA 2005). 

12 Ecological conditions in Pacific Coast estuaries are fair to poor. The water quality index for estuaries 

13 is good to fair. Poor water quality is mainly concentrated in south Hood Canal (Puget Sound) and 

14 San Francisco Bay. The DIN rating is good, with less than one percent exceeding concentrations of 

15 0.5 mg/L. DIP is considered fair, with concentrations exceeding 0.1 mg/L in San Francisco Bay and 

16 south Hood Canal. Water clarity is considered poor, especially in San Francisco Bay. Dissolved 

17 oxygen concentrations are good and hypoxia was only exhibited in two subestuaries of Puget Sound 

18 (EPA 2005). Sediment quality in Pacific Coast estuaries is fair to poor and toxicity is poor. There are 

19 high metal concentrations in San Francisco Bay and high metal and organic contaminants in Puget 

20 Sound and Los Angeles Harbor. ERM guidelines were exceeded in San Francisco Bay for chromium, 

21 mercury, and copper. In Southern California, DDT levels exceeded ERM guidelines. One site on the 

22 Columbia River exceeded ERM guidelines for either PAHs or PCBs. Three sites in Puget Sound also 

23 exceed these contaminant criteria. Los Angeles Harbor had high concentrations of metals and PAHs. 

24 Sediment TOC is considered good to fair. Los Angeles Harbor and Big Lagoon (in Northern 

25 California) are areas with high TOC (EPA 2005). 

26 Most of Alaska’s vast coastline has not been monitored for water quality. The majority of water 

27 resources are likely in pristine condition due to its size, sparse population, and remoteness. Water 

28 quality may be impaired around urban areas and near seafood processing facilities in the Aleutian 

29 Islands (EPA 2002). Only 0.1 percent of Alaska’s estuaries water quality has been assessed. Of this 

30 percentage, 89 percent are impaired and 11 percent are fully supporting designated uses. Only 0.1 

31 percent of the Alaska shoreline has been assessed. Thirty-six percent of the assessed shoreline water 

32 is impaired. Sixty-four percent of shoreline water is fully supporting designated uses (EPA 2005). 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-41 

1 An overall assessment of Alaska’s sediment quality has not been conducted. Harbors and bays have 

2 the potential to contain toxic sediments contaminated with PCBs, lead, dioxin, and petroleum 

3 products. 

4 Hawaii does not have a comprehensive coastal monitoring program. Water quality in Hawaii is 

5 variable, depending on storm water runoff. Storm water runoff decreases water quality as it carries 

6 pollutants into estuaries and coastal waters. Most industrial facilities and wastewater treatment plants 

7 discharge into coastal waters. Turbidity, nutrients, and pathogens from nonpoint source pollution 

8 also affect Hawaii’s water quality (EPA 2002). Water quality has been assessed in 99 percent of 

9 Hawaiian estuaries. Of this percentage, 57 percent is impaired and 43 percent is fully supporting 

10 designated uses. Eighty-three percent of shoreline waters have been assessed. Two percent of 

11 shoreline waters are impaired, 1 percent is threatened, and 97 percent is fully supporting designated 

12 uses (EPA 2005). An overall assessment of Hawaii’s sediment quality has not been conducted. 

13 Guam’s marine waters and bay sediments are generally free of pollutants, except in areas of localized 

14 pollutant runoff or where discharges from land or vessels occur. The deep surrounding seas rapidly 

15 dilute pollutant discharges (GEPA 2000). Of the bays assessed for water quality, three percent 

16 supported aquatic life and 65 percent supported swimming. Pollutants impacting water quality in 

17 these areas include pathogens, metals, suspended solids, urban runoff, and municipal facilities. The 

18 main cause of pollution in shoreline waters are microbial organisms (EPA 2002). Sediment quality 

19 has been assessed for four of Guam’s main harbors: Agana Boat Basin, Outer Apra Harbor, Agat 

20 Marina, and Merizo Pier. Overall the sites were relatively clean, including deeper water sediments. 

21 Most sites had high levels of copper, zinc, lead, and tin. Apra Harbor had the highest levels of these 

22 contaminants as well as PCBs and PAHs (GEPA 2000). 

23 Water quality in American Samoa is generally in good condition. Poor water quality conditions exist 

24 in populated areas where nutrient enrichment from human and animal wastes occurs. Heavy rains can 

25 bring sediments to coastal waters, a result of improper land use practices. Water and sediment quality 

26 in Pago Pago Harbor are in poor condition. Fish and substrates are contaminated with heavy metals, 

27 pesticides, and other pollutants. Previously, nutrient loading from cannery wastes caused algal 

28 blooms and fish kills. Wastes are now being dumped beyond the inner harbor (Craig 2002). Of the 

29 ocean shoreline assessed, 14 percent was impaired for aquatic life support. Fish consumption and 

30 swimming uses were impaired in 100 percent of the assessed shoreline (EPA 2002). Sediment quality 

31 information for the American Samoa is not available. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

3-42 

1 In the southern islands of CNMI, coastal water quality is impacted by sewage outfalls and overflows, 

2 septic systems, dredging, excess nutrients, and urban runoff. Sedimentation from unpaved roads and 

3 development increases turbidity in nearshore waters during heavy rains. High nutrient levels have 

4 negatively affected coral reefs and lagoons. Water quality data was collected in 2005 on Saipan, 

5 Tinian, Rota, and Managaha. In Saipan, 34 percent of coastal waters were non-supportive and 36 

6 percent were fully supportive of recreational uses. In Tinian and Rota, 64 percent were fully 

7 supportive of recreational uses, and no areas were non-supportive. All waters assessed on Managaha 

8 were fully supportive of recreational uses. Water quality near coral reefs was also monitored in 

9 2005. Twenty-eight percent of assessed waters were non-supportive of aquatic uses. Forty-eight 

10 percent were fully supportive of aquatic uses (Castro et al. 2006). Sediment quality information for 

11 CNMI is not available. 

12 3.4 Cultural Resources 

13 3.4.1 Definition of the Resource 

14 Cultural resources are prehistoric or historic remains, artifacts, or indicators of past human activities 

15 and accomplishments. They include “historic properties,” defined as prehistoric or historic sites, 

16 buildings, structures, or objects listed or eligible for listing on the National Register of Historic Places 

17 (NRHP). Artifacts, records, and physical remains associated with historic properties may be 

18 considered cultural resources (NRCS 2006). Other types of cultural resources include cultural or 

19 religious practices and Traditional Cultural Properties (TCPs). TCPs are properties associated with 

20 cultural practices or beliefs of a living community that are important in maintaining the continuing 

21 cultural identity of the community (Parker and King 1998). Examples of TCPs include: Native 

22 American ceremonial locations; urban neighborhoods that are the traditional home of a particular 

23 cultural group; and locations associated with the traditional beliefs of a Native American group. 

24 NEPA and CEQ regulations require Federal agencies to consider potential impacts on the “human 

25 environment,” which is defined as “the natural and physical environment and the relationships of 

26 people to that environment” (40 CFR 1508.14). Therefore, a Federal action must be analyzed for 

27 probable impacts on the cultural aspects of the human environment. The National Historic 

28 Preservation Act (NHPA) requires Federal agencies to consider the effects of their actions on historic 

29 properties (16 U.S.C. 470 et seq.). The Archeological and Historic Preservation Act requires Federal 

30 agencies to report any perceived impacts their actions may have on historical or archaeological data 

31 (including relics and specimens) (16 U.S.C. 469a et seq.). The Native American Graves Protection 
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1 and Repatriation Act requires the identification and appropriate disposition of human remains, 

2 funerary objects, sacred objects, or objects of cultural patrimony that are excavated on purpose or 

3 discovered inadvertently on Federal or tribal lands (25 U.S.C. 3001 et seq.). 

4 3.4.2 Affected Environment 

5 Prehistoric sites on land include shell middens, lithic scatters, habitation sites, burials, and ceremonial 

6 sites and sacred sites of early Native American populations. Other Native American cultural remains 

7 include domestic artifacts, stone tools, ivory objects, woven fishing nets, fiber-tempered pottery, 

8 masks, pictographs, and petroglyphs. Petroglyphs have been found on prominent boulders along the 

9 shoreline in Washington State (Stilson et al. 2003). 

10 In some coastal areas of the U.S., Native American tribes and other aboriginal peoples maintain 

11 strong cultural and subsistence ties to the environment and living natural resources, including marine 

12 mammals. This rich heritage may be traced to pre-history through art, language, tradition, or social 

13 customs. Native American villages located on the Pacific Coast depended on salmon, shellfish, and 

14 marine mammals for subsistence and cultural purposes. Whaling and sealing played a large role in 

15 the culture of tribes, including the Makah Tribe in Washington. The Makah hunted whales and used 

16 drift or stranded whales for subsistence uses, including food, tools, and trade. In the Pacific 

17 Northwest, Native American lands, trust resources, and tribal rights have been secured through 

18 treaties, statutes, judicial decisions, and EOs. NMFS administers its trust responsibilities, with 

19 respect to treaties, through government-to-government relationships with tribes. Present coastal tribes 

20 in Washington continue to use coastal resources for subsistence, ceremonial, and commercial 

21 activities. Important ceremonial resources include oysters, crabs, clams, salmon, bottomfish, kelp, 

22 seaweeds, sea urchins, and sea birds (OCNMS 1993). 

23 Alaska Natives use marine mammal parts for cultural handicrafts and harvest marine mammals for 

24 subsistence. The Inuit people of Arctic Alaska currently hunt ribbon seals (Phoca fasciata), ringed 

25 seals (Phoca hispida), bearded seals (Erignathus barbatus), spotted seals (Phoca largha), bowhead 

26 whales, gray whales, walrus, and polar bears. Alaska natives also harvest beluga whales in the 

27 Bering, Chukchi, and Beaufort Seas and Cook Inlet. Harbor seals are currently harvested throughout 

28 their range by coastal Alaska Natives. Northern fur seals are hunted in the Pribilof Islands. There is 

29 also a limited harvest of Steller sea lions and sea otters. Under the MMPA (Section 119), NMFS 

30 enters into cooperative agreements with Alaska Native organizations to co-manage subsistence and 

31 conserve marine mammals, including ice seals, harbor seals, fur seals, beluga whales, and bowhead 
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1 whales. Co-management agreements help meet species protection and recovery goals under the ESA 

2 and MMPA, while sustaining the traditional livelihoods of Alaska Natives. Alaska Native 

3 organizations also participate in marine mammal research and monitoring efforts. 

4 Prehistoric sites are prevalent in the Pacific Islands. Guam coastal areas include latte stones and 

5 ancient Chamorro artifacts. Latte stones were pillars which ancient Chamorro houses were built 

6 upon. Latte stones are inserted in sand containing fragments of pottery, shells, fish bones, charcoal, 

7 stone and shell tools. Burials in sand-lined pits have also been found near or under Latte stones. In 

8 American Samoa, habitation sites are expected to be located in coastal areas. Material remains found 

9 at these sites may include Lapita pottery, basalt flakes and tools, volcanic glass, shell fishhooks, shell 

10 ornaments, and faunal remains. Archaeological evidence indicates that early sites may be found on 

11 the shores of prehistoric embankments that have been filled in with sand. Remains of prehistoric 

12 villages may be visible on the surface, but many are buried underground (ASHPO 2006). 

13 Underground remains of prehistoric sites are also present in CNMI. Remains of Latte villages can be 

14 found on CNMI coastal stretches and may include petroglyphs and Latte stones. 

15 Archaeological sites in Hawaii include burial sites and TCPs. TCPs include volcanic cones, 

16 landforms associated with deities, and submerged coral formations which were once fishing locations. 

17 Habitation sites, burials, religious structures, and fishponds are present along the shoreline. Most 

18 sites are above the high-water mark and may be buried underneath the sand of many beaches. The 

19 largest known concentration of native Hawaiian burials is located on the Mokapu Peninsula, Oahu. 

20 This dune complex has been listed on the NRHP. The site was excavated for military purposes from 

21 1938-1940 and reburial efforts are being conducted (Cleghorn 2001). Archaeological historic sites 

22 below the high-water mark are typically fishponds, but anchor holes and petroglyphs have been 

23 documented. Most archaeological sites and TCPs in Hawaii have not been surveyed. It is likely that 

24 most coastline areas contain historic sites and resources (USCG 1999). In the Northwestern Hawaiian 

25 Islands, Nihoa and Necker Islands are both listed on the NRHP for their ceremonial and religious 

26 usage by Native Hawaiians. 

27 Many historic resources in the action area are listed on, or eligible to be listed on, the NRHP. These 

28 include lighthouses, ports, docks, coastal forts, and shipwrecks. The majority of historic sites in the 

29 Pacific Islands are areas from World War II. In American Samoa, Guam, and CNMI Japanese 

30 pillboxes and other coastal defenses can be found along the coastline. On CNMI, a mass grave of 

31 Japanese and U.S. military forces killed during battle is located on the coast (Cabrera 2005). Many 

32 shipwrecks are grounded on beaches throughout CNMI (CNMI 2001). 
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1 Submerged cultural resources include inundated archaeological sites, Native American artifacts, 

2 shipwrecks, and aircrafts. Native American artifacts include canoe runs, canoes, fish weirs, and 

3 petroglyphs (Stilson et al. 2003). Inundated archaeological sites found in nearshore areas include 

4 fishing weirs, bowls, donut stones, prehistoric stone anchors, historic metal anchors, and the remains 

5 of landings and wharfs. There is the potential for prehistoric sites offshore, where areas of the 

6 continental shelf were once shoreline. Archaeological surveys have not been conducted in most of 

7 these areas. American tanks that did not make landfall in CNMI sit in reef waters next to beaches 

8 (Cabrera 2005). 

9 3.5 Human Health and Safety 

10 3.5.1 Definition of the Resource 

11 A human health and safety risk is any hazardous, unhealthy, or unsanitary condition causing, or 

12 capable of causing, an unreasonable threat to the health, safety, and welfare of persons living or 

13 working in the vicinity of such condition. Human health and safety risks are present during response, 

14 rehabilitation, release, disentanglement, and research activities. Possible concerns for workers 

15 include physical injury, illness, exposure to contaminants, and ocean conditions. The Occupational 

16 Safety and Health Administration (OSHA) sets standards to assure safe and healthy working 

17 conditions and prevent work-related injuries and illnesses. OSHA requires employers to have health 

18 and safety plans. Employers must also maintain accurate records of employee work-related injuries, 

19 illnesses, deaths, and exposure to toxic materials or harmful physical agents. OSHA has laboratory 

20 standards for air contaminants and the risk of exposure to hazardous chemicals. 

21 Human health and safety risks may also affect the general public during normal beach and ocean 

22 activities, such as swimming, boating, and surfing. Possible concerns are drowning, illness, contact 

23 with marine animals, and exposure to contaminants. 

24 3.5.2 Affected Environment 

25 3.5.2.1 Marine Mammal Worker Safety 

26 Stranding Response. For authorized persons responding to strandings, hazards include physical 

27 injury, marine debris, zoonotic diseases, contaminant and toxin exposure, and exposure to the 

28 elements. In a survey of marine mammal workers, over half (54 percent) of the 483 respondents 

29 reported having at least one injury or illness believe to be the result of direct contact with marine 

30 mammals. Most injuries were cuts, scrapes, bites, and rashes (Mazet et al. 2004). Physical injuries 
Marine Mammal Health and Stranding Response Program 

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1 may occur from the stranded marine mammal. Stranded whales may thrash their flukes or roll over 

2 onto a person. Pinnipeds may attack and inflict serious bites that could become infected. Chemical 

3 exposure may occur if personnel are in contact with euthanasia solutions or other drugs. Other 

4 physical injuries include cuts from bone fragments and instruments. Lifting and rolling large animals 

5 and the use of heavy equipment can cause strains and bruises. Wet conditions can lead to slips, trips, 

6 falls, and possible drowning. Drowning is a risk during water rescues, especially if heavy surf 

7 conditions, dangerous undertows, or rip currents exist. Rescuers can become entangled in lines and 

8 nets used during water rescues, increasing the risk of drowning or other physical injury. The beach 

9 composition (fine sand, mud, cobble, boulder, etc.) can increase the difficulty of responding to 

10 strandings and may increase the risk of physical injuries. 

11 Marine debris is a hazard during stranding responses. Workers may be injured by stepping on broken 

12 glass, rusty metal, needles, or other litter. Workers could become entangled in derelict fishing gear 

13 during water responses. Workers may also come into contact with contaminated debris, including 

14 medical wastes and sewage. 

15 Reports of human illnesses from contact with marine mammals are rare, but have occurred. Marine 

16 mammals may carry infectious zoonotic diseases that may be transmitted to humans. Pathogens may 

17 be transmitted through direct contact with tissues, body fluids, or aerosols of the infected animals. 

18 These pathogens include, but are not limited to, Mycoplasma spp. (seal finger), Mycobacterium spp., 

19 Erysipelothrix sp., Leptospira sp., Brucella spp., seal poxvirus, and calicivirus. Seal finger typically 

20 occurs after a pinniped bite and can cause swelling and severe pain, especially in the joints of the 

21 hands. Seal poxvirus can cause painful skin lesions that may last up to a year. Leptospira can 

22 produce chills, headaches, myalgia, and eye pain in humans. Other organisms that infect marine 

23 mammals and could affect humans include Salmonella spp., Vibrio spp., Clostridium sp., parasites, 

24 and fungi (Mazet et al. 2004, Cowan et al. 2001). In the survey by Mazet et al. (2004), respondents 

25 reported dangerous infections, including tuberculosis, leptospirosis, and brucellosis. 

26 Marine animals in the water are a safety concern for marine mammal workers. Handling or stepping 

27 on coral can lead to cuts which may become infected. Jellyfish, including Portuguese man o’war, 

28 stings may cause minimal damage or fatal injuries. The defense mechanism of venomous fish (rays, 

29 scorpionfish, lionfish, etc.) can lead to bite or puncture wounds. Shark attacks are possible during 

30 response activities if workers are entering the water. Shark attacks are prevalent in U.S. coastal 

31 waters, with over 490 attacks since 1990. Of this number, 322 attacks have occurred in Florida; 53 in 

32 Hawaii; and 35 in California (FLMNH 2005). 
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1 Stranding responders may also be exposed to biotoxins from HABs. Most biotoxins are only a risk if 

2 contaminated seafood is consumed, except for brevetoxins. Aerosolized brevetoxins may be inhaled 

3 by humans and can cause respiratory problems, nausea, vomiting, and neurological symptoms. 

4 Responding to marine mammals contaminated with oil or other materials may cause lightheadedness; 

5 nausea; and eye, skin, and respiratory irritation (Geraci and Lounsbury 2005). 

6 Stranding responders are exposed to the elements and may suffer from sunburn, heat exhaustion, and 

7 heatstroke. Symptoms of heat exhaustion and heatstroke include profuse sweating, muscle cramps, 

8 nausea, dizziness, fever, and unconsciousness. Hypothermia may occur in cold weather and if 

9 responders are in cold water for long periods of time. Symptoms of hypothermia include weakness, 

10 drowsiness, confusion, uncontrollable shivering, and cold, pale skin. 

11 Disentanglement. Safety issues that may arise during disentanglement activities on water are related 

12 to aircraft operations, boating operations, the entanglement, physical and chemical restraint of the 

13 animal, and weather conditions. Safety hazards during aerial surveys to locate animals include 

14 collisions with another aircraft or a fixed object, mechanical failure, and crashes due to inclement 

15 weather conditions. 

16 During disentanglement operations, boating accidents may include collisions with another vessel or a 

17 fixed object, capsizing, a person falling overboard, and drowning. The risk of an accident may 

18 increase if boats come too close to the tail of the whale or if nets and lines foul the boat’s propeller. 

19 Pursuit of an entangled animal, rough seas, inclement weather conditions, and nightfall all increase 

20 the risk of a boating accident. Persons onboard have the potential to become entangled in nets, ropes, 

21 or buoys attached to the animal, increasing the risk of falling overboard. 

22 Physical injuries from disentanglement activities, both in water and on land, include bites from 

23 entangled animals, bruises, dislocations, and broken bones. Cuts may occur from instruments used to 

24 disentangle the animal. Other physical injuries may occur from contact with marine debris. 

25 Chemical exposure is possible during the administration of drugs for restraint, treatment, or 

26 euthanasia. 

27 Rehabilitation. Safety risks relative to rehabilitation include physical injury; zoonotic diseases; and 

28 contaminant, toxin, and chemical exposure. Rehabilitation personnel may incur physical injuries such 

29 as slips, trips, and falls from wet conditions around animal pools and pens. Lifting or moving animals 

30 may cause strains and bruises. Injuries to personnel working with animals in pools and pens include 
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1 bites, bruises, and drowning. Exposure to zoonotic diseases, contaminants, and toxins are potential 

2 risks to all personnel handling animals. Animal handlers in pools would be exposed to water 

3 contaminated with urine and feces. Chemical exposure is possible during the administration of drugs, 

4 including euthanasia solutions. 

5 Release. Release activities may cause strains, bruises, animal bites, or more severe physical injuries 

6 from moving animals for transport. Exposure to liquid nitrogen may occur during freeze branding 

7 procedures. During vessel releases, physical injuries could occur as a result of vessel collisions, 

8 capsizing, inclement weather, and rough waters. Sunburn, heat exhaustion, heat stroke, and 

9 hypothermia are possible, if release activities require people to be outside for extending periods of 

10 time. Physical injuries may occur from contact with marine debris. 

11 Research. Research activities conducted under the MMHSRP may occur in a laboratory and in or on 

12 the water. Safety issues in research laboratories include exposure to hazardous chemicals, flammable 

13 solvents, cryogenic liquids, air contaminants, biological agents, and UV radiation. Physical injuries 

14 such as cuts, punctures, bruises, and burns may occur while using laboratory equipment and 

15 materials. 

16 Research activities conducted in the water would typically be health assessment captures and releases. 

17 Risks include entanglement in nets, drowning, exposure to zoonotic diseases, cuts from instruments, 

18 accidental needle sticks, and injuries from freeze branding. Sunburn, heat exhaustion, and heatstroke 

19 may also occur, with symptoms including profuse sweating, muscle cramps, nausea, dizziness, fever, 

20 and unconsciousness. Hypothermia may occur in cold weather and if researchers are in cold water for 

21 long periods of time. Symptoms of hypothermia include weakness, drowsiness, confusion, 

22 uncontrollable shivering, and cold, pale skin. Jellyfish, sting rays, other venomous fish, and sharks 

23 all pose threats to researchers in water. Physical injuries could occur as a result of vessel collisions, 

24 capsizing, inclement weather, rough waters, and contact with marine debris. Slips, trips, and falls 

25 would also be hazards during research activities. 

26 3.5.2.2 Public Safety 

27 Public health and safety issues during recreational activities in the action area include pollution, 

28 marine debris, HABs, marine animals, marine debris, surf conditions, exposure to the elements, and 

29 boating operations. 
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1 A major public health concern in recreational waters is pollution. Pollutants entering the water 

2 include sewage, trash, medical wastes, oil or chemical spills, stormwater runoff, and boating waste. 

3 In 2004, sewage spills and overflow closed beaches for a total of 1,319 days. Stormwater runoff 

4 closed beaches for 4,144 days. These pollutants can contaminate the water with toxins, heavy metals, 

5 pesticides, bacteria, and viruses. Microbial infections include gastroenteritis, salmonellosis, 

6 shigellosis, giardiasis, skin rashes, and pinkeye. In 2004, beach advisories or closures occurred for 

7 approximately 14,615 days due to elevated bacteria levels. Viral infections can cause hepatitis; 

8 gastroenteritis; respiratory illness; and ear, nose, and throat problems (NRDC 2005). Marine debris is 

9 often found on beaches and the ocean floor. Beachgoers may be injured by stepping on broken glass, 

10 rusty metal, needles, or other litter or come in contact with contaminated debris. Swimmers and 

11 divers may get entangled in derelict fishing gear. 

12 Beaches may also be closed during a HAB event. Typically biotoxins from HABs are only hazardous 

13 if contaminated seafood is consumed. Inhalation of aerosolized brevetoxins can cause respiratory 

14 irritation, nausea, and neurological problems. 

15 Human interactions with stranded marine mammals are public health risks. As mentioned above, 

16 stranded animals can thrash around, roll onto, and attack humans. Consumption of marine mammals, 

17 which currently occurs in Alaska, may also be hazardous if animals have environmental contaminants 

18 or diseases. Zoonotic diseases can be passed if a person comes into contact with the animal or its 

19 body fluids. Coral, jellyfish, venomous fish, and sharks are marine animals that humans may 

20 encounter during recreational activities. 

21 Surf conditions include strong currents, rip currents, dangerous shorebreaks, and large and/or high 

22 waves. Hazardous surf conditions can cause injuries and drowning. Exposure to the elements can 

23 lead to sunburn, heat exhaustion, heatstroke, or hypothermia. 

24 Boating operations include motorboats, sailboats, personal watercraft (jet skis), and kayaks. In 2004, 

25 the top five types of recreational boating accidents were: collision with a vessel; collision with a fixed 

26 object; falls overboard; capsizing; and skier mishap. The causes of boating fatalities are drowning, 

27 trauma, and hypothermia. Contributing factors to accidents are reckless operations, excessive speeds, 

28 hazardous waters, alcohol use, operator inexperience, and machinery system failure. Most accidents 

29 occurred during fishing activities and waterskiing or tubing activities (USCG 2005). 
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1 3.6 Socioeconomics 

2 3.6.1 Definition of the Resource 

3 Socioeconomics are defined as the basic attributes and resources associated with the human 

4 environment, particularly population and economic activity. Population levels are determined by 

5 regional birth and death rates, as well as immigration and emigration. Economic activity typically 

6 encompasses employment, personal income, and industrial or commercial growth. The alternatives 

7 would not affect population levels within the action area; therefore this information will not be 

8 discussed. Important economic activities in the coastal regions of the U.S. include commercial, 

9 recreational, and subsistence fisheries; tourism; and other recreational activities. Other recreational 

10 activities conducted include clamming, beachcombing, surfing, boating, and planned events (festivals, 

11 sport tournaments, etc.). The alternatives have the potential to economically impact the MMHSRP 

12 rehabilitation facilities. Therefore, current costs of maintaining these facilities are discussed. 

13 EO 12898, Federal Actions to Address Environmental Justice in Minority and Low-Income 

14 Populations, requires Federal agencies to identify and address any disproportionately high and 

15 adverse human health or environmental effects their actions may have on minority and low-income 

16 populations. The alternatives are largely based upon marine mammal strandings and entanglements. 

17 Strandings and entanglements cannot be predicted and may occur anywhere on the coasts or in waters 

18 of the U.S. Potential effects of the alternatives would not occur with greater frequency for minority 

19 and low-income populations than for the general population as a whole. No environmental justice 

20 impacts would be expected from the alternatives and therefore will not be discussed further. 

21 3.6.2 Affected Environment 

22 Economic activities in coastal regions likely to intersect with one or more activities covered under 

23 this PEIS include industries encompassing stranding network participants (e.g., zoos and veterinary 

24 services) and tourism industries. Basic information for the relevant industries was obtained through 

25 the U.S. Economic Census. The information provided includes revenues, number of establishments, 

26 and number of employees by coastal states and territories (or if data was available at the county level, 

27 by aggregating data by coastal counties). Tabulations of this information are provided in Appendix 

28 M. 

29 Existing and potential members of the stranding network (and those who provide services to the 

30 network) are likely to fall into either two categories: zoos/botanical gardens and veterinary services. 
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1 The zoos and botanical gardens industry category is comprised of establishments primarily engaged 

2 in the preservation and exhibition of live plant and animal life and animal life displays, including 

3 aquaria. Since numerous SA holders are non-profits, statewide information for zoos and botanical 

4 gardens were also provided for those facilities with federal tax-exempt status. The veterinary services 

5 industry category is comprised of establishments of licensed veterinary practitioners primarily 

6 engaged in the practice of veterinary medicine, dentistry, or surgery for animals, as well as 

7 establishments primarily engaged in providing testing services for licensed veterinary practitioners. 

8 Summary information by state for these two industry categories are contained in Appendix M. The 

9 information for these industry categories include activities for the entire state, since some stranding 

10 activities related to those covered under the PEIS may occur further inland. 

11 Tourism industries which may be affected by the various activities in this PEIS include lodging and 

12 restaurants located adjacent to stranding activities. Since marine mammal stranding events occur in 

13 the water or on the beach, tourism-related businesses that are likely to be affected are those located on 

14 or near the ocean; therefore summary statistics for lodging and restaurants located in coastal counties 

15 are reported. Appendix M contains combined summary information for lodging and restaurant 

16 industries located in coastal counties. Lodging includes hotels, motels, bed and breakfasts, 

17 recreational vehicle parks, campgrounds, recreational camps and vacation camps. The restaurant 

18 category includes full-service restaurants, limited-service restaurants, cafeterias, snack bars, and bars. 

19 Stranding responses are usually short-term events. Most stranding responses last for a day. 

20 Responses to mass strandings of live animals may take several days. In tourist-based coastal 

21 economies, the economic input of stranding responders will be minimal and undetectable in regional 

22 economic statistics. 
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1 4. Environmental Consequences 

2 4.1 Introduction 

3 This section evaluates the potential direct and indirect environmental and socioeconomic impacts of 

4 the alternatives. Table 4-1 lists the alternatives considered in detail and their descriptions. Direct 

5 effects are caused by an action and occur at the same time and place as the action. Indirect effects are 

6 reasonably foreseeable effects caused by an action, but occur later in time or farther removed in 

7 distance from the action. CEQ regulations define the significance of impacts in terms of context and 

8 intensity. Context refers to the geographic area of effect, which varies with the setting of the 

9 alternatives and with each resource area being analyzed. Intensity refers to the severity of the impact 

10 and considers whether the effect would be negligible, minor, moderate, or major. Negligible impacts 

11 would not be detectable and would have no discernible effect. Minor impacts would be slightly 

12 detectable and would not be expected to have an overall effect. Moderate impacts would be clearly 

13 detectable and could have an appreciable effect. Major impacts would be clearly detectable and 

14 would have a substantial, highly noticeable effect. Duration, short-term or long-term, must be 

15 considered in the assessment of the environmental impacts. Short-term impacts are temporary and 

16 would generally end once the proposed activities have stopped. Long-term impacts are typically 

17 those effects that would last several years or more or would be permanent. Impacts were also 

18 evaluated in terms of whether they would be beneficial and/or adverse. 

19 Mitigation measures are methods to avoid, minimize, rectify, or reduce the adverse environmental 

20 impacts of an action. Mitigation measures are discussed in Section 5. These are measures that would 

21 be taken to avoid or minimize adverse effects of the proposed actions. 
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4-2 

1 Table 4-1. Alternatives Considered in Detail 

Alternative Description 

Stranding Agreements and Response 

Alternative A1 No Action- SAs expire, stranding response would end. 

Alternative A2 Status Quo- Current SAs would be renewed, current stranding 

response activities continue. Final SA criteria would not be 

issued. 

Alternative A3 SAs issued to any applicants after review, new SA template would 

not be utilized. Final SA criteria would not be issued. Current and 

future activities included. 

Alternative A4 (Preferred) Final SA criteria would be implemented, new SA template would 

be utilized, current and future activities included. 

Alternative A5 Final SA criteria would be implemented, new SA template would 

be utilized, and response to threatened, endangered, or rare 

animals would be required. 

Carcass Disposal 

Alternative B1 No Action- SAs expire, no carcass disposal would occur, carcasses 

would be left where stranded. 

Alternative B2 Status Quo- Current methods of carcass disposal continue. 

Alternative B3 (Preferred) Status Quo with the recommendation to transport chemically 

euthanized animal carcasses off-site. 

Rehabilitation Activities 

Alternative C1 No Action- Current SAs would expire, stranding response would 

cease, and animals would not be rehabilitated. 

Alternative C2 Status Quo- Current rehabilitation activities would continue. Final 

Rehabilitation Facility Standards would not be implemented. 

Alternative C3 (Preferred) New SAs would be issued, rehabilitation activities continue. Final 

Rehabilitation Facility Standards would be implemented. 

Alternative C4 New SAs would be issued, rehabilitation activities would continue. 

Rehabilitation of threatened, endangered, and rare animals would 

be required; response to other animals would be optional. Final 

Rehabilitation Facility Standards would be implemented. 

Release of Rehabilitated Animals 

Alternative D1 No Action- Current SAs would expire, stranding response and 

rehabilitation would cease, and therefore there would be no 

animals to release. 

Alternative D2 Status Quo- Current release activities would continue. Adaptive 

changes to release activities would not be permitted. Final release 

criteria would not be implemented. 

Alternative D3 (Preferred) New SAs would be issued, release activities continue. Final 

release criteria would be implemented and would include adaptive 

management of release activities. 

Disentanglement Activities 

Alternative E1 No Action- No disentanglement network. 

Alternative E2 Status Quo- Disentanglement network would continue current 

activities, no modifications or new members added. 

 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

4-3 

Table 4-1. Alternatives Considered in Detail (continued) 

Alternative Description 

Disentanglement Activities 

Alternative E3 (Preferred) Disentanglement network would continue current activities on East 

Coast with modifications to West Coast network. The 

Disentanglement Guidelines and training prerequisites would be 

implemented. 

Biomonitoring and Research Activities 

Alternative F1 No Action- Biomonitoring and research activities would not occur. 

Alternative F2 Status Quo- New ESA/MMPA permit would continue current 

biomonitoring and research activities. 

Alternative F3 (Preferred) New ESA/MMPA permit would be issued to include current and 

future biomonitoring and research activities. 

1 

2 4.2 Biological Resources 

3 This section evaluates the potential impacts on biological resources as a result of the alternatives. 

4 Impacts on biological resources are evaluated in context and intensity on a population or species-wide 

5 scale. Therefore, while more significant impacts may occur on individual animals, the overall impact 

6 on the population or species may still be considered minor. 

7 4.2.1 Stranding Agreements and Response Alternatives 

8 4.2.1.1 Alternative A1- No Action 

9 Under Alternative A1 stranding response from current SA (formerly LOA) holders would end once 

10 all agreements have expired. Federal (not including NMFS), state, and local agencies authorized 

11 under MMPA Section 109(h) would still be able to conduct emergency response to non-ESA listed 

12 species, and those ESA-listed species for which response is part of the 4(d) rule (see 50 CFR 

13 223.202(b)(2)). However, response activities would likely be limited and localized in extent, and 

14 would consist mostly of carcass disposal for the protection of public health and safety. The 

15 authorized level of stranding response would greatly decrease, ESA-listed marine mammals would 

16 not be responded to, animals in peril would not be hazed away from hazards, and more animals would 

17 likely perish. These animals would be removed from the population, which might have an adverse 

18 effect on species, especially those that are depleted, threatened, or endangered. There would be a lack 

19 of detection and notification of morbidity and mortality. The valuable information on marine mammal 

20 populations, such as biology, health, and disease detection, collected during the examination of 

21 stranded animals would no longer be collected. Scientists would not be able to study why strandings 

22 occur, which could indirectly affect future marine mammal populations. 
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4-4 

1 In addition, the ability of the stranding network to act as a surveillance network would be eliminated. 

2 This could result in the emergence and spread of marine mammal diseases, or the use and spread of 

3 fishery practices that were harmful to marine mammals, without any possibility for human 

4 intervention or mitigation until population-level effects were observed. At that point, it would likely 

5 be too late for any quarantine or translocation program to halt the spread of disease or for a fishery 

6 modification to occur. This could have adverse impacts on marine mammal populations, particularly 

7 those that are threatened or endangered, where the loss of a relatively small number of individuals 

8 represents a greater proportion of the species. One example would be the early detection of a disease 

9 such as Morbillivirus in the highly endangered Hawaiian monk seal (a naïve population). This 

10 outbreak could be mitigated by the isolation/translocation/captivity of affected individuals, but only if 

11 it was detected early in the spread of the disease, when few individuals had contracted the virus. 

12 In addition, other environmental conditions have been first detected in marine mammals or beach-cast 

13 seabirds, including oil spills and HABS. Early detection of these circumstances also allows the 

14 potential for human intervention (finding the source of the oil spill) and reducing the overall number 

15 of affected biological resources. When a significant number of strandings occur that share the same 

16 findings of fishery interaction, this information can be used to manage the fishery to reduce the 

17 impacts on marine mammals. Gear modifications, geographic changes (area closures), and temporal 

18 changes (season dates) may all be changed so that the probability of fishery interactions with marine 

19 mammal populations (particularly those that are threatened or endangered) is reduced. The stranding 

20 network provides critical information about potential issues when first observed, which allows for 

21 response and management before the problem becomes widespread and costly or impossible to 

22 ameliorate. 

23 No effects on protected and sensitive habitats, SAV and macroalgae, sea turtles, fish, shellfish, other 

24 invertebrates, and birds would be expected to occur under this alternative. Effects from leaving a 

25 carcass on the beach are described in Section 4.2.2.1, Carcass Disposal. 

26 4.2.1.2 Alternative A2- Status Quo 

27 Under Alternative A2, the current SAs would be renewed and current stranding response activities 

28 would continue without the issuance of Final SA criteria. Potential minor, short-term, adverse effects 

29 on all biological resources could occur from vessel and vehicle uses, but these impacts are expected to 

30 be negligible when compared to other inputs of hazardous materials from vessels, sewage outfalls, 

31 runoff, industrial operations, and other beach vehicle uses. Spills of hazardous materials or wastes 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

4-5 

1 from vessels during response to free-swimming animals could impact biological resources. Some 

2 materials could be diluted quickly by currents, only causing temporary impacts. Other materials 

3 could linger in the water column or adhere to sediment particles, causing slightly longer impacts. As 

4 with any activity, vehicular transport, heavy equipment, or medical equipment used during beach 

5 response activities could leak oil or other materials into sand and nearshore waters. These would 

6 likely be small amounts that would be flushed out and/or diluted rapidly, causing a minor and 

7 temporary impact. 

8 Minor, short- and long-term adverse effects on protected and sensitive habitats could occur during 

9 response activities. Equipment used for transport or response may traverse protected habitats to 

10 access a stranded animal. An animal may be stranded in a protected habitat and equipment might be 

11 needed for the response. Response activity could damage sand dunes and associated vegetation. 

12 Equipment may also cause compaction of the beach. Response equipment could also disturb or injure 

13 nesting sea turtles, depending on the location and time of year. Disturbance of a nesting sea turtle 

14 would likely be a short-term, minor impact. Injuring a nesting sea turtle and/or their eggs could 

15 produce minor, long-term effects, as all sea turtles are endangered species. 

16 Minor, short-term adverse effects on shellfish and other invertebrates living in the beach and intertidal 

17 environment could occur during response activities. The traversing of heavy equipment over shellfish 

18 beds could damage or kill shellfish. Digging with a shovel or spade to allow room for an animal’s 

19 flukes and flippers could also damage shellfish. 

20 Minor to moderate, short-term adverse effects on coastal and marine birds could occur during 

21 response activities. The use of equipment and the presence of people could disturb birds nesting or 

22 roosting in trees or small bushes, and may cause them to temporarily leave the area. Ground nesting 

23 birds could be adversely affected by response activities. Heavy equipment could crush nests and 

24 response personnel could disturb or damage a nest. Response activities conducted in shallow waters 

25 could disturb foraging birds. This impact would be minimal, as birds could forage in nearby areas 

26 and would likely return once response activities ended. 

27 Live stranded animals would most likely experience stress and pain due to the stranding event itself 

28 that could be decreased or increased by stranding response activities. The effects of stranding 

29 response activities on cetaceans would depend on the condition, species, and history of the animal. 

30 An alert and responsive animal may panic when responders approach. Mothers separated from their 

31 calves may become aggressive, and members of social species may experience negative effects from 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

4-6 

1 being separated from conspecifics. Debilitated animals that are weakly responsive or non-responsive 

2 animals may not physically, but may physiologically, react to responders. 

3 Healthy animals may be released immediately from the stranding site. Tagging may occur before the 

4 release in order to monitor the animal’s movements. Roto-tags would most commonly be used, but 

5 radio tags could be attached if available. During the attachment of the roto-tag, pain would only last 

6 during the application, and sedatives or local anesthetic would be used. The tag site could become 

7 infected, causing pain to the animal. Tissue damage or infection could occur when the tag is shed. 

8 For pinnipeds, animal movement may prolong or prevent healing by producing repetitive stress on the 

9 tag site. Epoxy would be used to attach radio tags to pinnipeds and should not cause pain if done 

10 properly. However, it may result in discomfort if the placement of the instrument causes pulling of 

11 the hair or skin during animal movement. In addition, if the ratio of resin and hardener is not 

12 correctly measured, the resulting heat-producing reaction could burn the animal’s skin. Both the resin 

13 and hardener could cause skin irritation, such as itching, rashes, hives, and dermatitis. The instrument 

14 could be knocked or torn off, pulling out hair and possibly some of the underlying skin, which would 

15 then be open to infection. 

16 During mass strandings, animals may be marked with a grease pen, crayon, or zinc oxide to keep 

17 track of each animal. These materials would not cause an impact on marine mammals. 

18 Handling, lifting, and moving an animal may cause injuries to the animal, including stress and 

19 increased shock. Flippers may be crushed or the animal may overheat if stretchers do not have 

20 openings for them. Creases or seams in stretchers and transport equipment may press into the skin, 

21 causing discomfort, pain, and possible temporary or permanent injuries. Chemical immobilization of 

22 a cetacean can be life threatening, if not administered and monitored correctly. When anesthetized, 

23 an animal may go into a dive reflex, which would include breath holding, slowing of the heart rate, 

24 and the pooling of blood from peripheral vessels. While under anesthesia, a cetacean may develop 

25 hypothermia. If the animal is not in water, improper body support could compromise cardiac and 

26 respiratory functions (Haulena and Heath 2001). During transport to a rehabilitation facility, animals 

27 may overheat in direct sun and heat without protection. Depending on body condition, cetaceans may 

28 overheat (hyperthermia) or develop hypothermia during transport. Body surfaces may be exposed to 

29 the drying effects of air. Animals may also be knocked around, causing muscle damage or they may 

30 inhale exhaust fumes. Improper transport of cetaceans may cause abrasions, pressure necrosis, 

31 thermoregulatory problems, and respiratory problems. Muscular stiffness may occur from transport, 

32 but most accepted transport methods try to minimize or avoid this entirely. Stiffness would disappear 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

4-7 

1 within a few hours to a few days, unless there was permanent muscle damage (Antrim and McBain 

2 2001). 

3 Beach response activities for live stranded pinnipeds would require physical capture of the animal. 

4 Captures may disrupt other animals, including conspecifics, if the capture occurs at a haul-out site or 

5 any other area where animals were located. Impacts would be expected, as non-target animals may 

6 flee into the water. Pups and young animals may be trampled or abandoned. Juvenile and adult 

7 animals may be trampled and killed during stampedes or injured on rocks and cliff faces. If animals 

8 were not injured, impacts would be minor and short-term as animals would likely return once 

9 responders have left. Handling and restraint, if not properly executed, may further injure or kill a 

10 pinniped (e.g. suffocation under the weight of a handler). Chemical immobilization (anesthesia or 

11 sedation) of a pinniped has risks, especially in ill or injured animals, if not administered and 

12 monitored correctly. When anesthetized or sedated, an animal may go into a dive reflex, which 

13 would include breath holding, slowing of the heart rate, and the pooling of blood from peripheral 

14 vessels. Pinnipeds may develop hypo- or hyperthermia while anesthetized. Transport to a 

15 rehabilitation facility may cause muscular stiffness or damage. Stiffness would disappear within a 

16 few hours to a few days, unless there was permanent muscle damage (Antrim and McBain 2001). 

17 Without protection, animals may overheat in direct sun and heat or develop hypothermia or frostbite 

18 in freezing temperatures. Inhalation of exhaust fumes and jolting during transport could injure 

19 pinnipeds. 

20 Response may also include the harassment and/or capture of free-swimming animals that are trapped, 

21 out of habitat, extralimital, or exhibiting abnormal behavior. Reactions to vessel close approaches 

22 and hazing activities from cetaceans may include swimming faster, breaching, diving, tail and fin 

23 slapping, or moving away from the vessel. Pinniped reactions to vessels are highly variable, 

24 depending on the species (Calkins and Pitcher 1982). Behaviors in response to close approaches by 

25 vessel would generally be short-term, with a minimal effect on the animal. 

26 Any capture and/or restraint procedure would likely have some effect on the behavior or activities of 

27 marine mammals. The method(s) of restraint, as well as the age and general condition of the animal 

28 are all factors that would affect an animal’s response to capture. Animals could incur contusions, 

29 concussions, lacerations, nerve injuries, hematomas, and fractures in their attempts to avoid capture or 

30 escape restraint (Fowler 1978). The stress response could change an animal’s reaction to many 

31 drugs, including those commonly used for chemical restraint, which could have lethal consequences. 

32 Stress could also alter an animal’s immune system. It may also lead to behavioral changes including 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

4-8 

1 increased aggressive and antisocial tendencies (Fowler 1986). Stress from capture and restraint could 

2 cause capture myopathy, which occurs when an animal cannot cool itself (Fowler 1978). Capture 

3 myopathy is characterized by degeneration and necrosis of striated and cardiac muscles and usually 

4 develops within 7 to 14 days after significant trauma, stranding, transport, or capture. Animals could 

5 also become entangled in the capture net, which may result in injuries or death. Animals may become 

6 stressed during handling and restraint. Signs of stress in cetaceans include reduced respiration, 

7 prolonged struggling while being held, and arching. Impacts on pinnipeds from capture and restraint 

8 are described above. 

9 Response would include hazing an animal(s) when necessary to move it away from a possible health 

10 hazard. Potential adverse effects of hazing would likely be from the close approach of vessels, either 

11 used to deploy hazing methods or as a method itself. The intent of the activities would be to cause 

12 the animal to change their behavior and move away from a potential threat. Acoustic deterrent 

13 methods may cause temporary physical discomfort, but would not likely cause long-term injuries. 

14 The use of airguns around mysticetes is a concern because of their ability to hear low frequencies 

15 better than odontocetes. Concern with using mid-frequency sonar is the close range impacts on 

16 harbor porpoise, minke whales, Steller sea lions, and other species. The use of seal bombs near 

17 highly volatile oil is also a concern. Exclusion devices used for pinnipeds would not have a 

18 significant impact, as animals would not become trapped or entangled. Overall, no significant, long19 term impacts to behavior would be expected with proper mitigation. A beneficial impact would be 

20 expected from hazing because it would likely prevent an animal from being harmed. 

21 Biological samples may be collected from a stranded animal to help determine the medical and 

22 physiological condition of the animal, assess the best course of action, and monitor progress and 

23 appropriateness of treatment. Samples would include blood, swabs, biopsies, etc. Sample collection 

24 would likely cause minor stress to the animal, beyond the actual stranding event. Response activities 

25 would be conducted in an attempt to save an animal’s life, to reduce pain and suffering, or to 

26 humanely euthanize an animal, which would be deemed in the best interest of the animal. Most 

27 adverse impacts on stranded animals would be outweighed by the potential beneficial impacts of 

28 saving an animal and/or reducing their pain and suffering. 

29 Response activities would also include euthanasia, when deemed necessary. Euthanasia procedures 

30 would be performed by the attending veterinarian or a person acting on behalf of the attending 

31 veterinarian. All euthanasia procedures would follow the AVMA guidelines (AVMA 2001) and/or 

32 the AAZV guidelines (AAZV 2006). Chemical euthanasia agents may cause hyperexcitability or 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

4-9 

1 violent reactions in some species. Intraperitoneal administration of a euthanasia solution may lead to 

2 the prolonged onset of action due to differential or slow absorption rates. It may also cause irritation 

3 in the surrounding tissues. Improperly administered chemical euthanasia agents or methods of 

4 delivery may prolong the pain and suffering of an animal. When done correctly, the use of ballistics 

5 should cause instantaneous unconsciousness followed by respiratory and cardiac arrest. However, 

6 improper uses, such as inappropriate caliber of the firearm or untrained personnel, may not cause 

7 unconsciousness before death and would then not be considered humane under the AVMA 

8 guidelines. During mass strandings, the use of ballistics may stress and exacerbate fear in the 

9 surviving animals. The incorrect charge placement of explosives may not cause instantaneous 

10 unconsciousness and may cause tissue destruction (Greer et al. 2001). Exsanguination (bleeding) 

11 may prolong pain and suffering if done incorrectly. 

12 Issuance of SAs only to current SA holders limits the activities of the stranding network to the 

13 geographic area that is currently covered. Animals may strand in areas where response is limited or 

14 non-existent. Limited response may increase the pain and suffering of stranded animals, and animals 

15 would likely die without response from the stranding network. Limiting the issuance of SAs would 

16 not allow for new rehabilitation facilities to be added and would affect the amount of animals that 

17 could be accepted for rehabilitation. If current rehabilitation facilities do not have space for an 

18 animal, the animal would be euthanized or left on the beach during response activities. Prohibiting 

19 new activities could reduce the success of a response, as new tools and techniques would not be 

20 available for use. 

21 Implementing the SA criteria would ensure that only those individuals, organizations, or institutions 

22 qualified and trained to conduct response, assessment, rehabilitation, and/or release of marine 

23 mammals would be given SAs. This would reduce the likelihood of increased risks to wild 

24 populations with release. Without using the criteria during the review of SA applicants, 

25 inexperienced personnel could be issued a SA to respond to and/or rehabilitate stranded animals. 

26 Inexperienced personnel could put the animal’s health in jeopardy, increase their pain and suffering, 

27 and increase the adverse impacts on other biological resources. The potential for an appropriate 

28 response (immediate release, animal to rehabilitation, or euthanasia) would decrease. Without a 

29 nationwide set of criteria, SA holders in different NMFS regions may not be held to the same 

30 standards or require the same minimum experience and qualifications. This would include working 

31 with a licensed veterinarian for live animal response and rehabilitation to ensure animals receive 

32 adequate and humane care. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

4-10 

1 4.2.1.3 Alternative A3 

2 Under Alternative A3, SAs would be issued to any applicants after review, the new SA template 

3 would not be utilized, and the Final SA criteria would not be issued. Current and future stranding 

4 response activities would be included in this alternative. Effects on biological resources from 

5 stranding response activities under Alternative A3 would be the same as those described under 

6 Alternative A2. Effects of not implementing the SA criteria would also be the same as those 

7 described under Alternative A2. Under Alternative A3, as new techniques and tools become 

8 available they could be permitted for use during response activities. This would likely have a 

9 beneficial impact on marine mammals as response efforts would be conducted using the best 

10 available equipment and methods. 

11 Minor, adverse effects on marine mammals would be expected to occur if new SAs are issued to any 

12 applicant after they were reviewed by the appropriate NMFS Regional Office. Inexperienced 

13 individuals may be responding to stranded marine mammals, which could result in injuries or 

14 inhumane techniques. Some beneficial impacts could come from allowing new SA holders to be 

15 added, given that they have the proper experience with marine mammal response, as geographic 

16 coverage would increase and new rehabilitation facilities may be added to the Stranding Network. 

17 4.2.1.4 Alternative A4- Preferred Alternative 

18 Under Alternative A4, the Final SA criteria and the new SA template would be implemented and 

19 current and future stranding response activities would occur. Effects on biological resources from 

20 stranding response activities under Alternative A4 would be the same as those described for 

21 Alternative A2. Under Alternative A4, as new techniques and tools become available they could be 

22 permitted for use during response activities. This would likely have a beneficial impact on marine 

23 mammals as response efforts would be conducted using the best available equipment and methods. 

24 Modifications could also be made to euthanasia techniques if safer, more effective methods or 

25 chemical euthanasia solutions are developed. The use of new techniques and tools would have 

26 impacts similar to, or less than, those described under Alternative A2. 

27 Long-term beneficial effects on marine mammals would be expected to occur with the 

28 implementation of the SA template and criteria. The template contains the requirement for periodic 

29 review and reapplication in order to stay in the stranding network. Reviews would occur by the 

30 Regional NMFS Office after the first year for new (probational) network members, every 3 years for 

31 members doing live animal response and rehabilitation, and every 5 years for organizations 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

4-11 

1 responding solely to dead animals. In addition, the new agreement provides NMFS with the option to 

2 place organizations on probation or suspension, or to terminate the SA, for noted deficiencies or 

3 failure to comply with the terms and conditions of the SA. The SA criteria would make certain that 

4 SA holders in every NMFS region were held to the same standards and require the same minimum 

5 experience and qualifications. A licensed veterinarian would be highly recommended during all 

6 emergency response activities and during the transport of cetaceans. A licensed veterinarian would 

7 be required at all rehabilitation facilities. This attending veterinarian would meet qualifications as set 

8 forth in the Minimum Criteria and Rehabilitation Facility Guidelines, including: 1) having an active 

9 veterinary license in the U.S. (has graduated from a veterinary school accredited by the AVMA 

10 Council on Education, or has a certificate issued by the American Veterinary Graduates Association's 

11 Education Commission for Foreign Veterinary Graduates) or has received equivalent formal 

12 education as determined by NMFS; and 2) having the appropriate registrations and licenses (e.g., for 

13 handling controlled substances, including registering with the Drug Enforcement Administration 

14 [DEA]) to obtain the necessary medications for marine mammal response. This would likely increase 

15 the potential for an appropriate response, rehabilitation, and/or release, and may minimize the 

16 negative impacts associated with stranding response on biological resources. New SA holders could 

17 be added under the alternative, which would be a beneficial impact on marine mammals. 

18 4.2.1.5 Alternative A5 

19 Under Alternative A5, the Final SA criteria and the new SA template would be implemented and 

20 response to threatened, endangered, or rare animals would be required. Effects on biological 

21 resources from stranding response activities under Alternative A5 would be the same as those 

22 described under Alternative A2. Effects on biological resources from the implementation of SA 

23 criteria would be the same as those described under Alternative A4. 

24 Requiring response to threatened, endangered, or rare animals would be a positive effect on those 

25 populations. However, making response to other animals optional could adversely affect those 

26 populations as they could become threatened or endangered in the future. It may also indirectly affect 

27 ESA-listed species, as non-listed species often serve as models for other animals. Limiting response 

28 to non-listed species would decrease the information gained from strandings that could be beneficial 

29 to the survival of threatened and endangered species. Responding to other species allows the 

30 detection of new diseases or hazardous conditions in the ocean, which may reduce impacts on 

31 threatened and endangered species or species of concern. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

4-12 

1 4.2.2 Carcass Disposal Alternatives 

2 4.2.2.1 Alternative B1- No Action 

3 Under Alternative B1, no carcass disposal would occur and carcasses would remain on the beach to 

4 naturally decompose. Federal (not including NMFS), state, and local agencies authorized under 

5 MMPA 109(h) would still be able to conduct carcass disposal of non-ESA listed species. Carcass 

6 disposal activities would likely be limited and localized. Carcasses would likely be removed to avoid 

7 having a decomposing animal on a public beach. Animal carcasses may contain POPs, toxic metals, 

8 pathogens, and/or biotoxins. Contaminant levels would likely be higher in species that feed at higher 

9 trophic levels and/or in areas where prey may be more contaminated. A literature review has been 

10 conducted to determine the persistent contaminants found in selected marine mammal species (see 

11 Appendix J). Species addressed in the review were based upon the frequency and patterns with which 

12 they strand. The review concluded that there is a limited amount of information on most species and 

13 their contaminants. Therefore, the evaluation of the potential toxicological environmental hazards 

14 posed by a decomposing carcass cannot be determined at this time. 

15 4.2.2.2 Alternative B2- Status Quo 

16 Under Alternative B2, current methods of carcass disposal would continue. Current carcass disposal 

17 methods under Alternative B2 include on-site burial, transport off-site (for burial or rendering), 

18 disposal at sea, and natural decomposition (left on-site). Spills of hazardous materials or wastes from 

19 vessels during at-sea carcass disposal activities could impact biological resources. Some materials 

20 could be diluted quickly by currents, only causing temporary impacts. Other materials could linger in 

21 the water column or adhere to sediment particles, causing slightly longer impacts. Biological 

22 resources could be injured or killed if they are in the vicinity of a spill. Equipment used during 

23 carcass disposal activities could leak oil or other materials into sand and nearshore waters. Hazardous 

24 material leaks from equipment could impact shellfish, other invertebrates, and nearshore fish. 

25 However, these would likely be small amounts that would be flushed out and/or diluted rapidly, 

26 causing a minor, short-term impact. However, all of these impacts would be negligible when 

27 compared to other inputs of hazardous materials from vessels, sewage outfalls, runoff, industrial 

28 operations, and other beach vehicle uses. 

29 Digging physically alters and disrupts the site. However, effects would be negligible as on-site burial 

30 would not be conducted in protected and sensitive habitats without consulting the proper authorities 

31 (see Section 5.2). Potential damage could occur as equipment may need to traverse sensitive habitats 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

4-13 

1 to access the carcass for removal or disposal. Equipment used for disposal at sea and the carcass 

2 itself could hit and damage submerged sensitive habitats, such as coral reefs. 

3 Animal carcasses may contain POPs, toxic metals, pathogens, and/or biotoxins. Contaminant levels 

4 would likely be higher in species that feed at higher trophic levels and/or in areas where prey may be 

5 more contaminated. The evaluation of the potential toxicological environmental hazards posed by a 

6 decomposing carcass cannot be determined at this time (see Appendix J). However, the potential 

7 does exist for the decay products of carcasses to be released into the surrounding environment or 

8 recycled into the food web, with subsequent negative impacts. 

9 Animals may also contain chemical residues from substances administered by stranding response 

10 personnel, including chemical euthanasia solution and sedatives. If the animal is a rehabilitated 

11 animal that has restranded, it may also contain antibiotics, antifungals, and other medicine. These 

12 chemicals persist in the carcass at different concentrations and for different amounts of time. They 

13 would not likely create a large-scale environmental hazard, as the levels would be negligible 

14 compared to levels found in runoff and sewer discharge, and the compounds are not likely to 

15 bioaccumulate through the food web. 

16 Contaminants from potentially toxic carcasses left on site or buried could leach into groundwater and 

17 flow into nearshore water, harming sensitive areas in and around the carcass. This impact would be 

18 minor and short-term. If contaminants enter groundwater, they would likely be flushed out quickly 

19 by tidewater and/or precipitation. Higher concentrations of contaminants may occur in nearshore 

20 waters down site from the carcass. These concentrations would be diluted and flushed out by the 

21 currents; therefore the impact on biological resources would be temporary and minor. Sediment 

22 quality would not likely be impacted by contaminants, as they would be flushed out or diluted before 

23 they could adhere to the substrate. Therefore, any organisms using sediment would not be impacted. 

24 SAV and macroalgae could be indirectly affected by on-site burial. Contaminants from chemically 

25 euthanized carcasses could leach into groundwater and impact waters used by SAV and macroalgae. 

26 Carcass disposal at sea could cause minor, short-term, adverse effects. Equipment used for disposal 

27 at sea and the carcass itself could potentially damage SAV and macroalgae or remove SAV from 

28 sediment. Impacts would be minor, as SAV and macroalgae would grow back and organisms that use 

29 them as habitat would be able to utilize surrounding areas. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

4-14 

1 On-site carcass burial could adversely affect sea turtles nesting on beaches, depending on the location 

2 and time of year. However, carcass burial sites would not be sited near nesting sea turtles, 

3 eliminating the potential for adverse effects. 

4 Minor, short-term adverse effects on coastal and marine birds could occur during carcass disposal. 

5 The use of equipment and the presence of people could disturb birds nesting or roosting in trees or 

6 small bushes, and may cause them to temporarily leave the area. These birds would likely return to 

7 the area once response activities ended and impacts would be temporary, as response activities would 

8 occur for a short period. Ground nesting birds could be adversely affected by transport and burial 

9 activities. Heavy equipment could crush nests and digging for burial could completely remove a nest. 

10 Personnel helping with disposal could disturb or damage a nest. 

11 Minor, short-term adverse effects on shellfish and other invertebrates could occur during response 

12 activities. The traversing of heavy equipment over shellfish beds to access a carcass could damage or 

13 kill shellfish. Shellfish would not be negatively impacted during digging for carcass burial, as burial 

14 sites would be chosen well above the high tide line. Other invertebrates could be disturbed and 

15 negatively impacted during burial activities. Contaminants from toxic carcasses could leach into 

16 groundwater and nearshore waters and impact shellfish. Potential effects on fish may result from 

17 contaminants in nearshore waters. Impacts on shellfish and fish from contaminants would be minor, 

18 as contaminants would be flushed out and/or diluted rapidly. 

19 Scavengers may be adversely affected if carcasses of chemically euthanized or toxic animals are left 

20 to decompose on the beach. Euthanasia solution is toxic and may injure or kill animals feeding on 

21 these carcasses, known as secondary toxicosis. In addition, scavengers may consume POPs, other 

22 toxic chemicals, and biotoxins which may bioaccumulate over time, with the potential for serious 

23 injuries or death. Diseased animal carcasses may also cause serious injuries or death if consumed by 

24 scavengers. Likewise, disposal of these carcasses at sea could also affect scavengers, such as sharks 

25 and seabirds. Negligible, short-term, adverse effects on scavengers would be expected to occur from 

26 the removal of carcasses from beaches. Carcasses provide food many animals, including foxes, 

27 coyotes, birds, and polar bears. Threatened bald eagles may feed on marine mammal carcasses left on 

28 beaches. California condors, an endangered species recently reintroduced in California, may also 

29 feed on marine mammal carcasses. California condors would not be affected, as most carcasses 

30 (mainly pinnipeds that have not been chemically euthanized) are left on beaches in California where 

31 the condors are located. Effects of carcass removal are expected to be negligible because scavengers 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

4-15 

1 are not solely dependent on marine mammal carcasses for survival. In most areas, strandings are rare 

2 and not a major component of scavengers’ diets. 

3 Minor, indirect benefits may occur from carcasses towed out to sea. Disposal at sea of carcasses may 

4 create food for other organisms. However, this may lead to recycling of contaminants. Large whale 

5 carcasses have been known to become habitat and food for a variety of organisms, such as those as 

6 seen on natural whale falls (Smith and Baco 2003). Some stranding network members have 

7 coordinated carcass disposal efforts with research groups studying whale falls and the transitory 

8 benthic invertebrate communities surrounding them. 

9 4.2.2.3 Alternative B3- Preferred Alternative 

10 Under Alternative B3, current methods of carcass disposal would continue with a recommendation to 

11 transport chemically euthanized animal carcasses off-site. Effects from Alternative B3 would be the 

12 same as those described under Alternative B2, except for the effects from chemically euthanized 

13 animal carcasses. Under Alternative B3, these carcasses would be transported off-site to a proper 

14 landfill whenever possible, removing the risk of contamination. This would be a positive effect on 

15 protected and sensitive habitats, SAV and macroalgae, fish, shellfish, other invertebrates, and 

16 scavengers. 

17 Under this alternative, modifications may be made to carcass disposal activities. Currently, the 

18 potential toxicological environmental hazards posed by a decomposing carcass are not known. If and 

19 when this information becomes available, additional precautions (e.g., removal of certain species 

20 carcasses from beaches) would be implemented, if necessary. These modifications would have a 

21 beneficial impact on the surrounding biological resources. 

22 4.2.3 Rehabilitation Activities Alternatives 

23 4.2.3.1 Alternative C1- No Action 

24 Under Alternative C1, current SAs would expire, stranding response would end, and animals would 

25 not be taken into rehabilitation. Marine mammals not taken into rehabilitation most would likely die 

26 from injuries or disease. For populations that are endangered, this could potentially affect the 

27 survival of the species. No effects on protected and sensitive habitats, SAV and macroalgae, sea 

28 turtles, fish, shellfish, other invertebrates, or birds would be expected to occur from this alternative. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

4-16 

1 4.2.3.2 Alternative C2- Status Quo 

2 Under Alternative C2, current rehabilitation activities would continue, but the final Rehabilitation 

3 Facility Standards would not be implemented. Stranded animals would be taken into rehabilitation 

4 with the intent to release them back to the wild, if possible, once they are healthy. Biological samples 

5 may be collected from a stranded animal to help determine the medical and physiological condition of 

6 the animal, assess the best course of action, and monitor progress and appropriateness of treatment. 

7 Samples would include blood, swabs, biopsies, etc. Sample collection would likely cause minor 

8 stress to the animal, beyond the actual stranding event. Handling, lifting, and restraining an animal 

9 could cause injuries. When anesthetized or sedated, an animal may go into a dive reflex, which 

10 would include breath holding, slowing of the heart rate, and the pooling of blood from peripheral 

11 vessels. Anesthetized animals could develop hypothermia or hyperthermia. Administration of drugs 

12 and surgical procedures could cause injuries or death. However, all rehabilitation activities would be 

13 conducted in an attempt to help sick and injured animals. Rehabilitation would be conducted with 

14 proper veterinary oversight and the use of established and accepted methods. Most adverse impacts 

15 on animals in rehabilitation would be outweighed by the potential beneficial impact of saving an 

16 animal and returning it to the wild. 

17 Animal euthanasia may occur, when deemed necessary by the attending veterinarian. Euthanasia 

18 procedures would be carried out by, or under the direction of, the attending veterinarian. Chemical 

19 euthanasia agents may cause hyperexcitability or violent reactions in some species. Intraperitoneal 

20 administration of a euthanasia solution may lead to the prolonged onset of action due to differential or 

21 slow absorption rates. It may also cause irritation in the surrounding tissues. Improperly administered 

22 chemical euthanasia agents or methods of delivery may prolong the pain and suffering of an animal. 

23 Current facilities may not have enough space or resources to accommodate a stranded animal or may 

24 only rehabilitate certain animals. If no rehabilitation facility can take an animal, the animal may be 

25 euthanized. Standards for the humane treatment of marine mammals would constantly be developed, 

26 applied, and re-examined. Practices currently acceptable may not be acceptable in the future. If 

27 adaptive changes are not allowed, the success of rehabilitation would not increase. Animals may not 

28 be able to return to the wild, which may mean the animal would be euthanized or placed into 

29 permanent captivity in a public display or research facility. Removal of marine mammals from the 

30 wild would negatively effect populations that are depleted, threatened, or endangered. 
Marine Mammal Health and Stranding Response Program 

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1 The Rehabilitation Facility Standards would not be implemented, compromising animal health, the 

2 success of rehabilitation, and the potential for release to the wild. Inadequate care may increase pain 

3 and suffering of a marine mammal. Pool and pen sizes could be inadequate or contain too many 

4 animals, which would restrict animal movement and may cause aggressive behaviors between 

5 animals. New animals may not be placed into quarantine, which could introduce new pathogens to 

6 other animals currently in the rehabilitation facility, which are already compromised. Pathogens may 

7 also be introduced and spread through contaminated supplies, equipment, and personnel, by mixing of 

8 marine mammal species within the rehabilitation setting (particularly species that do not interact or 

9 whose ranges do not overlap in the wild), or by encounters between marine mammals and terrestrial 

10 mammals (particularly canids, felids, and raccoons). Any pathogen within a rehabilitation “hospital” 

11 setting has the potential to mutate or evolve into a novel organism (including those with drug resistant 

12 properties), creating a new (or drug-resistant) disease which could then be introduced into the naïve 

13 wild population upon the release of an infected animal following rehabilitation, particularly if the 

14 animal is not thoroughly evaluated prior to release. 

15 4.2.3.3 Alternative C3- Preferred Alternative 

16 Under Alternative C3, new SAs would be issued, rehabilitation activities would continue, and the 

17 final Rehabilitation Facility Standards would be implemented. The effects on marine mammals from 

18 rehabilitation activities under this alternative would be the same as those described under Alternative 

19 C2. No effects on protected and sensitive habitats, SAV and macroalgae, sea turtles, fish, shellfish, 

20 other invertebrates, or birds would be expected to occur from rehabilitation activities under this 

21 alternative. 

22 The Rehabilitation Facility Standards would be implemented, requiring current and future facilities to 

23 adhere to the minimum standards as part of their SA. The standards would ensure a healthy 

24 environment for animals, maximize the success of rehabilitation, and increase the potential for release 

25 to the wild. The standards cover facilities, housing, space, water quality, quarantine, sanitation 

26 practices, food handling and preparation, and veterinary medical care. Rehabilitation facilities would 

27 be required to submit the maximum holding capacity for their facility based upon the minimum space 

28 requirements in order to minimize overcrowding. Long-term beneficial impacts would be expected, 

29 as these standards would ensure that safe, healthy, and humane conditions are in place at all facilities. 

30 The standards would decrease the risk of disease transmission within the facility with the 

31 requirements for quarantine facilities and quarantine protocols for all incoming animals. Minimum 

32 quarantine and biosecurity standards include, but are not limited to: having separate filtration and 
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1 water flow systems; providing sufficient space or solid barriers between animal enclosures to prevent 

2 direct contact; and maintaining equipment and tools strictly dedicated to the quarantine area. 

3 Additional quarantine standards are described under mitigation in Section 5.2.3. 

4 Veterinary medical care standards (Sections 1.7 [for cetaceans] and 2.7 [for pinnipeds] in the 

5 Rehabilitation Facility Standards) would ensure that veterinarians and other personnel have the 

6 appropriate knowledge and experience to properly care for and treat marine mammals. An attending 

7 veterinarian would be required to work with staff at all rehabilitation facilities and be involved in 

8 making decisions regarding medical care and husbandry of current and incoming animals. Veterinary 

9 care standards, including recommended standards, are described under mitigation in Section 5.2.3. 

10 Standards for open ocean/bay net pens reduce the probability of disease transmission to other healthy 

11 animals in the pens or the wild population and ensure that good water quality would be maintained. 

12 Even with these standards, adverse impacts from the use of net pens may occur. Animals in net pens 

13 are still exposed to conditions that cannot be controlled, such as water temperature, HABs, and the 

14 elements. The recommended placement of net pens may not always be feasible due to geography, 

15 currents, proximity to protected areas, or proximity to economic interests (e.g., aquaculture). The use 

16 of temporary pools may adversely affect animal health. Proper water quality and temperature may 

17 not be maintainable and disease transmission may occur if more than one animal is housed in a pool. 

18 Animals in outside temporary pools would also be exposed to the elements. 

19 Under this alternative, modification of rehabilitation activities could occur. Rehabilitation activities 

20 may change with improvements in technologies, techniques, and other aspects of marine mammal 

21 medicine. These new activities would have impacts similar to, or less than, those currently 

22 conducted. The closure of rehabilitation facilities is also included under modification of activities. 

23 Animals being held at a facility would be transferred to the nearest available rehabilitation facility in 

24 the region. Impacts from the transfer of animals would include handling, lifting, restraint, and 

25 transport. Impacts from handling, lifting, and restraint are the same as those described under 

26 Alternative C2. 

27 During transport, cetaceans may overheat (hyperthermia) or develop hypothermia during transport. 

28 Body surfaces may be exposed to the drying effects of air. Improper transport of cetaceans may 

29 cause abrasions, pressure necrosis, thermoregulatory problems, and respiratory problems. Muscular 

30 stiffness may occur from transport, but most accepted transport methods try to minimize or avoid this 

31 entirely. Stiffness would disappear within a few hours to a few days, unless there was permanent 
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1 muscle damage (Antrim and McBain 2001). Animals may also be knocked around, causing muscle 

2 damage or they may inhale exhaust fumes. 

3 4.2.3.4 Alternative C4 

4 Under Alternative C4, new SAs would be issued, rehabilitation activities would continue, and the 

5 final Rehabilitation Facility Standards would be implemented. The rehabilitation of threatened, 

6 endangered, and rare animals would be required and the rehabilitation of other animals would be 

7 optional. The effects on marine mammals from rehabilitation activities under this alternative would 

8 be the same as those described under Alternative C2. No effects on protected and sensitive habitats, 

9 SAV and macroalgae, sea turtles, fish, shellfish, other invertebrates, or birds would be expected to 

10 occur from rehabilitation activities under this alternative. The effects on marine mammals would be 

11 the same as those described under Alternative C3. 

12 Adverse impacts would also be expected for animals that are not rare, threatened, or endangered. 

13 Rehabilitation of all other animals would not be required, but would be optional depending on facility 

14 resources. Animals not taken into rehabilitation would be euthanized on the beach. These animals 

15 often serve as models for other species and provide valuable information that could be used during 

16 rehabilitation. For example, through the treatment and care of California sea lions (a commonly 

17 stranded pinniped along the West Coast) husbandry practices have been refined and are used to the 

18 benefit of Steller sea lions (a threatened species), including nutrition; stress reduction; animal 

19 monitoring; and veterinary techniques including drugs, sedatives, and anesthetics. Similarly, 

20 rehabilitation practices refined on Northern fur seals from the non-listed San Miguel stock off the 

21 California coast benefit Northern fur seals from the depleted Eastern Pacific stock, as well as 

22 endangered Guadalupe fur seal. Information obtained from California sea lions regarding impacts of 

23 disease and environmental conditions, such as domoic acid, provide valuable data regarding food web 

24 transfer and exposure routes, possible treatment options, and population-impacts. Due to similar 

25 physiology, much of this information may be extrapolated to other otariid species including Steller 

26 sea lions and Northern fur seals to determine how these animals may be exposed (via the food web) 

27 and affected, as well as treated. In addition, animals from the “common” species are frequently 

28 placed with rare, threatened or endangered animal to provide adequate non-human socialization. 

29 Absence of common animals, and lack of experience treating them, would lead to difficulties in 

30 adequately treating rare, threatened and endangered species. This would be an indirect adverse affect 

31 on rare, threatened, and endangered species. 
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1 4.2.4 Release of Rehabilitated Animals Alternatives 

2 During the public comment period, particular concerns were raised regarding the release of 

3 rehabilitated ices seals in Alaskan waters. In response to these concerns, which raised issues both 

4 related to potential impacts on biological resources (conspecifics or other wild ice seal populations) 

5 and potential effects on cultural resources for subsistence harvest of ice seals, several of the 

6 alternatives would adopt mitigation measures to minimize the potential for disease transmission from 

7 rehabilitated ices seals, as described in Section 5.2.4 of this PEIS. 

8 4.2.4.1 Alternative D1- No Action 

9 Under Alternative D1, current SAs would expire, stranding response and rehabilitation would cease, 

10 and there would be no animals to release. All marine mammals brought in for rehabilitation would 

11 remain in captivity or be euthanized. This alternative would reduce potential impacts on wild 

12 populations, as there would no longer be the risk of introducing a diseased animal that could 

13 potentially infect other marine mammals. However, it would eliminate the potentially beneficial 

14 effects of returning animals to the wild population. No effects on protected and sensitive habitats, 

15 SAV and macroalgae, sea turtles, fish, shellfish, other invertebrates, or birds would be expected to 

16 occur from release activities under this alternative. 

17 4.2.4.2 Alternative D2- Status Quo 

18 Under Alternative D2, current release activities would continue, adaptive changes to release activities 

19 would not be permitted, and the final Release criteria would not be implemented. Minor, short- and 

20 long-term adverse effects on protected and sensitive habitats, SAV and macroalgae, sea turtles, fish, 

21 shellfish, and birds could occur from release activities under this alternative. Spills of hazardous 

22 materials or wastes from release vessels could impact these resources. Some materials could be 

23 diluted quickly by currents, only causing temporary impacts but others could linger in the water 

24 column or adhere to sediment particles, causing slightly longer impacts on sensitive habitats, SAV, 

25 and macroalgae. Hazardous materials could injure or kill sea turtles or marine mammals in the 

26 vicinity of a spill. Equipment used for beach release activities could leak oil or other materials into 

27 sand and nearshore waters. Sea turtles and birds could be injured and their nests may be damaged. 

28 These materials would likely be flushed out and/or diluted rapidly, causing a minor, short-term 

29 impact to sensitive habitats, SAV and macroalgae, fish, shellfish, and other invertebrates. 

30 As required under regulations at 50 CFR 216.27, all animals would be tagged or marked prior to 

31 release. Commonly used methods of tagging delphinids include freeze branding on or below the 
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1 dorsal fin (both sides of the body) and/or the attachment of a roto-tag (cattle ear tag) to the dorsal fin. 

2 Freeze branding may cause little or momentary pain during application, which would require 15-20 

3 seconds per brand. Initial discomfort or pain would be relieved by the appropriate anesthetic or 

4 analgesic. Discomfort may persist for some time after the procedure, but is expected to be minor. 

5 Therefore, impacts would be considered negligible and not significant. However, liquid nitrogen 

6 could spill onto an animal during the process, causing more than momentary pain. During the 

7 attachment of the roto-tag, pain would only last during the application, and sedatives or local 

8 anesthetic would be used. However, the tag site could become infected, causing pain to the animal. 

9 When the tag is shed, tissue damage may occur and the site could become infected. NMFS must be 

10 contacted if other additional tagging methods may be used, including radio, satellite, or microchip 

11 (Passive Integrated Transponder [PIT] tags) (see Section 4.2.6.2 for impacts from other tagging 

12 methods). For cetaceans other than delphinids, NMFS must be contacted to determine the appropriate 

13 identification method(s). 

14 Pinnipeds would be given flipper tags (roto-tags), with placement dependent on the species. Tags 

15 would be attached to the hind flipper of phocids and the foreflipper of otariids (Geraci and Lounsbury 

16 2005). Flipper tagging would cause temporary pain during attachment and the tag site may become 

17 infected. The tag may also be ripped out and the site could become infected. Animal movement may 

18 prolong or prevent healing by producing repetitive stress on the wound. Additional tagging may 

19 include radio, satellite, or microchip (PIT) tags with a variety of attachment methods (see Section 

20 4.2.6.2 for impacts from other tagging methods). 

21 Tagging allows an individual animal to be monitored after being released and evaluate its success in 

22 returning to the wild (Lander et al. 2001). If released animals appear to be compromised (e.g., not 

23 feeding, ill, or interacting with people) based on tag data, animals could potentially be recaptured for 

24 further rehabilitation or permanent captivity. This would be beneficial to the individual animal and 

25 may also protect the wild population by preventing disease transmission or transfer of negative 

26 behaviors, such as human interaction. Conversely, if the tag data indicates that the animal is behaving 

27 “normally” (diving to depths indicative of feeding, swimming in normal patterns, in geographic 

28 association with other animals of the same species, avoiding people), the rehabilitation may be 

29 deemed a success, and the tag can provide basic biological data about the animal and species. For 

30 instance, the first rehabilitation and release of a Risso’s dolphin occurred at the Riverhead Foundation 

31 for Marine Research and Preservation in New York (DiGiovanni et al. 2005). After release, this 

32 animal was tracked for 67 days. Aerial over flights showed that it was in the vicinity of other Risso’s 
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1 dolphins and that it was diving up to a maximum of 600 m depth for a maximum duration of 15 

2 minutes. This rehabilitation effort was deemed to be a success, based on this follow-up information. 

3 This is also some of the first information that has been collected on a free-ranging Risso’s dolphin, so 

4 it is beneficial to basic scientific inquiries about marine mammals. For some marine mammal 

5 species, particularly those that are offshore or cryptic, tagging may be the only way to monitor these 

6 animals and gather necessary life history data (Wilson and McMahon 2006). Over time, data may be 

7 collected from a significant number of released animals (particularly those that commonly strand) that 

8 can provide population-level insights into species movement and behavior patterns. 

9 Tagging and post-release monitoring is also beneficial in the evaluation and improvement of 

10 response, rehabilitation, and release procedures. For example, cetaceans that mass strand in the 

11 Northeast U.S. (particularly Cape Cod) are not typically rehabilitated, and are either euthanized or 

12 refloated and released off the beach. While animals that are pushed out are not generally observed 

13 restranded in the area, their ultimate fate has been unknown. Recently, satellite transmitters were 

14 deployed on two beach-released Atlantic white-sided dolphins that were part of separate mass 

15 stranding events (Rice and Cooper 2005). Both animals were tracked for over 30 days, and the tracks 

16 indicated survivorship as well as vigorous swim and dive behavior following return to offshore 

17 habitats. Some studies are also being done on classes or groups of animals that strand due to a 

18 common etiology (cause), such as domoic acid in California pinnipeds. California sea lions that have 

19 been deemed successfully rehabilitated (passed all of the pre-release screening tests) have been 

20 tracked post-release and determined to have long-term medical and behavioral problems that persist 

21 from the domoic acid intoxication, including seizures, disorientation, isolation, and not reacting to 

22 approach from humans and dogs (Thomas and Harvey 2005). Several animals restranded, and the 

23 behavior of others made survivability questionable. As a result, rehabilitation decisions are being re24 examined for this and other species, including the definition of a “successful” rehabilitation. 

25 Transport of animals to release sites could cause stress or injuries to an animal. During transport to 

26 the release site, animals may overheat in direct sun and heat without protection. Cetaceans may 

27 overheat (hyperthermia) or develop hypothermia during transport. Body surfaces may be exposed to 

28 the drying effects of air. Animals may also be knocked around, causing muscle damage or they may 

29 inhale exhaust fumes. Improper transport of cetaceans may cause abrasions, pressure necrosis, 

30 thermoregulatory problems, and respiratory problems. Muscular stiffness may occur from transport, 

31 but most accepted transport methods try to minimize or avoid this entirely. Stiffness would disappear 
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1 within a few hours to a few days, unless there was permanent muscle damage (Antrim and McBain 

2 2001). 

3 The release of pinnipeds on rookeries or haul-out sites could disrupt other animals. When pinnipeds 

4 are startled and disperse from rookeries, pups may be trampled or abandoned. Juvenile and adult 

5 animals may be trampled during stampedes or injured on underwater rocks and cliff faces. 

6 Animals deemed releasable after rehabilitation would be returned to the wild, which may have a 

7 positive or negative impact on marine mammal populations. Without the use of release criteria, 

8 animals that are not medically, developmentally, or behaviorally cleared for release could be released. 

9 Releasing unhealthy animals could increase their pain and suffering. An animal that is not healthy or 

10 has behavioral issues could re-strand or die, which would counteract the care it received in 

11 rehabilitation. Animals that are not healthy could transmit diseases to wild populations (Cunningham 

12 1996, Measures 2004). An animal that is not behaviorally ready for release may not have the skills 

13 needed to survive in the wild. The animal may not be able to forage or avoid predators. An animal 

14 may have abnormal breathing and may be unable to swim or dive properly. Animals with behavioral 

15 issues could also approach, interact, and be aggressive with people, creating hazard to themselves and 

16 public safety. 

17 4.2.4.3 Alternative D3- Preferred Alternative 

18 Under Alternative D3, new SAs would be issued, release activities would continue, adaptive changes 

19 to release activities would be permitted, and the final Release criteria would be implemented. Effects 

20 on protected and sensitive habitats, SAV and macroalgae, sea turtles, fish, shellfish, birds, and marine 

21 mammals from release activities under Alternative D3 would be the same as those described under 

22 Alternative D2, except for the impacts on marine mammals. Beneficial effects would be expected for 

23 marine mammals because the release criteria would be implemented and adaptive changes would be 

24 permitted. 

25 Under the release criteria, animals would be medically cleared by the attending veterinarian and their 

26 assessment team before a release determination is made. The medical assessment would include a 

27 hands-on physical examination and a review of the animal’s complete history, diagnostic test results, 

28 and medical and husbandry records. These procedures would minimize the risk of disease 

29 introduction or transmission to the wild population. 
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1 Animals would also be developmentally and behaviorally cleared before release occurred, enhancing 

2 their chance for survival. Developmental clearance would ensure that the animal has attained a 

3 sufficient age to be nutritionally independent, including the ability to forage and hunt. Behavioral 

4 clearance would include an assessment of an animal’s breathing, swimming, diving, locomotion on 

5 land (pinnipeds) foraging, and hunting abilities. An evaluation of an animal’s visual and auditory 

6 functions would be conducted. For cetaceans, any behavioral conditioning would be eliminated prior 

7 to release such that the association of food rewards with humans is diminished. 

8 An animal that has recovered from an infectious disease would be released near its original stranding 

9 site, when feasible, in order to minimize disease risks to the wild population. NMFS must be 

10 consulted when an animal cannot be released near their original stranding site to determine a 

11 preferred release site. 

12 Adaptive changes would allow the use of new procedures and technology, such as tags and telemetry 

13 packages. New tags and telemetry packages would likely be smaller in size and weight and less 

14 invasive than those currently used. Impacts from these new activities would be similar to, or less 

15 than, those impacts described under Alternative D2 for current tagging activities. The release criteria 

16 may change as new information and data are obtained from released animals and as improvements are 

17 made in marine mammal medicine. New procedures and technologies may also increase the success 

18 of a release and the survival of an animal. 

19 4.2.5 Disentanglement Alternatives 

20 4.2.5.1 Alternative E1- No Action 

21 Under Alternative E1, there would be no disentanglement network. No significant effects on 

22 protected and sensitive habitats, SAV and macroalgae, sea turtles, fish, shellfish, or birds would be 

23 expected to occur from Alternative E1. However, gear on an entangled animal may be shed and 

24 become marine debris, which could potentially harm biological resources. The amount that may be 

25 shed would be negligible compared to the amount of gear already in the ocean. 

26 Lines and gear may cause serious injuries to animals and restrict their ability to move, dive, and feed. 

27 If an animal cannot free itself from the entangling material it would most likely die. Without 

28 disentanglement efforts, animals would likely suffer a slow, painful death. North Atlantic right 

29 whales would be greatly affected if disentanglement efforts ceased, as entanglements are known to be 

30 a significant source of mortality. The best estimate of the size of the North Atlantic right whale 
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1 population is a range of 300 to 350. Although other population size estimates are available, the most 

2 recent Stock Assessment Report (Waring et al. 2007) indicates that the best estimate minimum 

3 population size for the species is 313 individually-recognized whales known to be alive in 2002. 

4 Recent models indicate that this population is likely declining, rather than remaining static or 

5 increasing (Caswell et al. 1999). The loss of one individual, especially a reproductively healthy 

6 female, would be a major impact on the species. For biological reasons, the number of reproductive7 age females is more essential to a species’ ability to maintain itself or grow than the number of males. 

8 Humpback whales and other large endangered whales would also be negatively affected if 

9 disentanglement activities ended. 

10 4.2.5.2 Alternative E2- Status Quo 

11 Under Alternative E2, the disentanglement network would continue the current activities with no 

12 modifications or new members added. Minor, short-term adverse effects on protected and sensitive 

13 habitats, SAV and macroalgae, sea turtles, fish, shellfish, other invertebrates, and birds could occur 

14 from this alternative. Spills of hazardous materials or wastes from vessels could impact these 

15 biological resources. Some materials could be diluted quickly by currents, only causing temporary 

16 impacts. Other materials could linger in the water column or adhere to sediment particles, causing 

17 slightly longer impacts. No impacts would be expected to occur during pinniped disentanglements on 

18 land. 

19 Under Alternative E2, the disentanglement network would continue to disentangle or attempt to 

20 disentangle animals. Removal of life-threatening gear would not only increase the chance of survival 

21 for the individual animal, but would have a positive impact on those species that are threatened and 

22 endangered. These activities pose minimal adverse and significant beneficial impacts to the 

23 entangled animal. 

24 Minor adverse effects on marine mammals could occur during disentanglement activities. Takes of 

25 entangled animals would occur during close approaches by aircraft (to locate entangled animals or for 

26 photo-identification) or by vessel (for documentation, general assessment, photo-identification, and 

27 disentanglement attempts). Incidental takes from close approaches are likely if other animals are in 

28 the vicinity of the entangled animal. Aerial surveys to locate entangled animals would be of a short29 duration and aircraft would circle at an altitude ranging from 300-1,000 ft (91-305 m) above the 

30 animal. Harassment of marine mammals could occur if the aircraft operated below a certain altitude. 

31 Aerial surveys may cause an animal to change its behavior, such as diving rapidly. However, this 
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1 change in behavior would be short-term, with a minimal effect on the animal. Responders have 

2 reported that whales they have encountered have not exhibited evasive behavior in response to aerial 

3 approaches for the purpose of photo-identification and basic sighting data. 

4 Animal reactions to close approaches may include swimming faster, breaching, diving, tail and fin 

5 slapping, or moving away from the vessel. Responders have reported that some whales encountered 

6 for assessment and documentation have not exhibited evasive behavior. Whales encountered closely 

7 (within 30 m) for the purpose of tagging and disentanglement efforts did exhibit evasive behavior in 

8 response to vessel approaches. These behaviors would generally be short-term, with a minimal effect 

9 on the animal. Response of the entangled animal to disentanglement attempts depends upon the 

10 species. Humpback whales are relatively easy to handle, especially if they have been entangled for a 

11 prolonged period of time. Experience has indicated that humpbacks are unlikely to be evasive or 

12 aggressive during disentanglement efforts, however there are always exceptions. Right whales tend 

13 to respond with aggressive behavior and are uncooperative. To decrease reactions from animals, 

14 approaches would be slow and from the side or behind, with minimal noise. Standby vessels 

15 maintain some distance to minimize potential whale disturbance. 

16 During attempts to physically restrain whales, floats, buoys, and control lines would be attached. 

17 Right whales have been known to tow numerous floats and drag moderate-sized vessels. Physical 

18 restraint of the animal may increase stress or pain. Physical restraint of a pinniped may also cause 

19 injuries or death. Chemical restraint may lower a free-swimming whale’s respiratory rate, slow their 

20 breathing, and decrease their swimming strength. Sedatives may be delivered through a blow-dart 

21 style syringe, which may startle the animal and cause it to react. Chemical restraint of a pinniped 

22 may initiate the dive reflex, which would include breath holding, slowing of the heart rate, and the 

23 pooling of blood from peripheral vessels. The short-term effects from physical and chemical 

24 restraints would be outweighed by the potential beneficial outcomes. 

25 Potential injuries may occur when cutting line and gear off the animal. Unintentional injuries may 

26 occur as an animal moves while cutting or if control of the equipment is lost. Responders may 

27 intentionally injure an animal, when no options to safely remove gear exist and only after 

28 consideration of the possible damage. The potential for a positive outcome outweighs the short-term 

29 effects of these injuries. Potential injuries could also occur if there are hazardous material spills from 

30 vessels, including stand-by vessels, during disentanglement activities. These occurrences could cause 

31 injury or death to marine mammals in the vicinity. 
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1 During large whale disentanglement, biopsy sampling may occur via remote dart. Animal reactions 

2 to remote biopsy darting are discussed under Section 4.2.6.2, biopsy sampling. Responders report 

3 that while there is typically a low level of evasive response to the close approach for the biopsy 

4 sample, there have not been obvious reactions to the biopsy dart itself. Samples of skin or other 

5 tissue may be recovered from removed fishing gear and would have no impacts on animals. 

6 During small cetacean disentanglement, the animal typically must be captured utilizing in-water 

7 capture techniques, such as encirclement via hoop net, followed by physical restraint. Additional 

8 animals may be captured or harassed during the rescue attempt. During pinniped capture and 

9 disentanglement activities, non-entangled animals may be disturbed off a haul-out site. 

10 Potential adverse effects could occur, as the addition of new network members would not be allowed. 

11 Without the addition of new members, entangled animals may not be responded to, decreasing their 

12 chance of survival and increasing their pain and suffering. Modifications are not allowed, including 

13 new techniques and tools which could increase the success of disentanglement. Guidelines and 

14 training prerequisites which are currently utilized on the East Coast would not be implemented 

15 nationwide, which may mean inexperienced people could be conducting disentanglement activities on 

16 the West Coast. This would likely increase risks to already vulnerable entangled animals and the 

17 surrounding environment, as well as decrease the success of a disentanglement attempt. 

18 4.2.5.3 Alternative E3- Preferred Alternative 

19 Under Alternative E3, the disentanglement network would continue the current activities on the East 

20 Coast with modifications to the West Coast network. The disentanglement guidelines and training 

21 prerequisites would be implemented. Effects on protected and sensitive habitats, SAV and 

22 macroalgae, sea turtles, fish, shellfish, and birds from Alternative E3 would be the same as those 

23 described under Alternative E2. Effects on marine mammals from close approaches, physical 

24 restraint, chemical restraint, and cutting of lines would be the same as those described under 

25 Alternative E2. 

26 Major, long-term beneficial effects on marine mammals would be expected under Alternative E3. 

27 The disentanglement network would continue to disentangle or attempt to disentangle whales. 

28 Removal of life-threatening gear would not only increase the chance of survival for the individual 

29 animal, but would have a positive impact on those species that are threatened and endangered. New 

30 members could be added to the network which would increase the number of animals responded to. 

31 Guidelines and training prerequisites would be implemented nationwide, helping ensure that only 
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1 experienced and qualified individuals are engaged in disentanglement activities. This would likely 

2 increase the success of disentanglement and decrease the potential risk to entangled animals and the 

3 surrounding environment. 

4 Disentanglement activities may be modified under this alternative, as new techniques and tools are 

5 developed. New tools may include safer, more effective cutting instruments and new telemetry 

6 buoys. Chemical and physical restraint techniques may be improved, including the administration of 

7 sedatives and the attachment of buoys, floats, and control lines. These new activities would have 

8 impacts similar to, or less than, those currently used during disentanglement activities. 

9 4.2.6 Biomonitoring and Research Activities Alternatives 

10 4.2.6.1 Alternative F1- No Action 

11 Under Alternative F1, biomonitoring and research activities would not occur. No effects on protected 

12 and sensitive habitats, SAV and macroalgae, sea turtles, fish, shellfish, or birds would be expected to 

13 occur from Alternative F1. Both beneficial and adverse effects on marine mammals would be 

14 expected. Biomonitoring and research activities would end and therefore takes of marine mammals 

15 would also end. This would be beneficial to animals, as they would no longer experience any 

16 negative impacts from these activities. However, without these research activities, important health 

17 and exposure data on marine mammal populations would no longer be collected. This would limit 

18 information on exposure of marine mammals to chemical and biological toxins. It would also hinder 

19 some research on the adverse health effects of toxin exposure for marine mammals and would restrict 

20 investigations into factors for UMEs. This could impede future conservation and management 

21 actions and ultimately result in detrimental impacts on marine mammal populations, especially those 

22 that are threatened and endangered. 

23 4.2.6.2 Alternative F2- Status Quo 

24 Under Alternative F2, the new ESA/MMPA permit would continue the current biomonitoring and 

25 research activities. Potential minor, short-term, adverse effects on all biological resources could occur 

26 from vessel and vehicle uses. Spills of hazardous materials or wastes from vessels could impact 

27 biological resources. Some materials could be diluted quickly by currents, only causing temporary 

28 impacts. Other materials could linger in the water column or adhere to sediment particles, causing 

29 slightly longer impacts. Equipment used during beach research activities could leak oil or other 

30 materials into sand and nearshore waters during beach releases. These would likely be small amounts 

31 that would be flushed out and/or diluted rapidly, causing a minor, short-term impact. However, all of 
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1 these impacts would be negligible when compared to other inputs of hazardous materials from 

2 vessels, sewage outfalls, runoff, industrial operations, and other beach vehicle uses. 

3 Potential minor, short-term, adverse effects on protected and sensitive habitats could include damage 

4 from vessels or researchers in the water or on the beach. Coral reefs and other habitats may be 

5 damaged from contact with a vessel or a person. 

6 Negligible, short-term adverse effects on SAV and macroalgae could occur during research activities. 

7 Vessels used during research activities conducted in shallow waters may damage SAV and 

8 macroalgae with their propellers. Vessel operators would be aware of this potential impact and would 

9 avoid these areas, where feasible. Any damage to SAV and macroalgae would be negligible and 

10 short-term, as only a minimal amount would be disturbed and would grow back. 

11 Minor to major, short- and long-term effects on sea turtles could occur during research activities. 

12 Activities conducted on beaches could disrupt nesting sea turtles or damage their nests. 

13 Minor, short-term adverse effects on coastal and marine birds could occur during research activities. 

14 The close approach by vessels or aircraft, the use of equipment, or the presence of researchers on 

15 beaches could disturb birds nesting or roosting in trees or small bushes, and may cause them to 

16 temporarily leave the area. Ground nesting birds could be adversely affected by research activities. 

17 Equipment could crush nests and research personnel could disturb or damage a nest. Research 

18 conducted in nearshore waters could disturb foraging birds. This impact would be minimal and 

19 temporary, as birds could forage in nearby areas and would likely return once research activities 

20 ended. 

21 Beneficial and adverse effects on marine mammals would be expected to occur from Alternative F2. 

22 Indirect beneficial effects would occur because valuable information on marine mammals and marine 

23 mammal health trends would be collected. This information would be used to understand stranding 

24 events, UMEs, and basic biological processes. Under this alternative, new research activities could 

25 not be conducted. This would limit the ability to collect information in areas not currently studied or 

26 to utilize new technologies and techniques during research activities. This would likely have a 

27 negative impact on marine mammals. 

28 Adverse effects on marine mammals from biomonitoring and research activities would be expected to 

29 occur under this alternative. Takes of marine mammals would occur from close approaches, 

30 euthanasia, capture and restraint, tagging, marking, and biological sampling. General methodologies 
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1 used for biomonitoring and research are described in Appendix H and their impacts are described 

2 below. The numbers of estimated takes are listed in Appendix I. 

3 Close Approach, Vessel and Aerial Surveys. Takes of animals would occur during close approaches 

4 by vessel or aircraft. Close approaches would occur during numerous research activities such as 

5 health assessment, biopsy sampling, breath sampling, tagging, photo identification, and collection of 

6 sloughed skin and feces. Incidental takes of non-targeted animals, including USFWS species, from 

7 close approaches are likely if they are in the vicinity of the targeted animal(s). Reactions from 

8 cetaceans may include swimming faster, breaching, diving, tail and fin slapping, or moving away 

9 from the vessel. Cetacean reactions to aerial surveys depend on the aircraft’s altitude, length of pass, 

10 and species or individual behaviors. Approaches to marine mammals below certain altitudes may 

11 harass marine mammals and cause a change in behavior, or elicit behaviors, such as diving rapidly. 

12 Behaviors in response to close approaches by vessel and aircraft would generally be short-term, with 

13 a minimal effect on the animal or the population. 

14 Pinniped reactions to vessels and aircraft are highly variable, depending on the species (Calkins and 

15 Pitcher 1982). In Steller sea lion studies, reactions ranged from none to complete and immediate 

16 departure from the haul-out site. In most cases, the potential impact to the animal is limited to 

17 disturbance; with the animal remaining at the haul-out site. When pinnipeds are startled and disperse 

18 from rookeries, pups or young may be trampled or abandoned. Juvenile and adult animals may be 

19 trampled during stampedes or injured on underwater rocks and cliff faces. The incidence of 

20 stampedes in response to aerial surveys at specific altitudes is unknown. Disturbance from aerial 

21 surveys would be dependent on plane specifications, flight patterns, and the altitude. 

22 Capture, Restraint, and Handling. Any capture and/or restraint procedure would likely have at least 

23 some short-term effect on the behavior or activities of marine mammals. The number of times an 

24 animal would be captured, the method(s) of restraint, as well as the age and general condition of the 

25 animal are all factors that would affect an animal’s response to capture. Animals could incur 

26 contusions, concussions, lacerations, nerve injuries, hematomas, and fractures in their attempts to 

27 avoid capture or escape restraint (Fowler 1978). The stress response could change an animal’s 

28 reaction to many drugs, including those commonly used for chemical restraint, which could have 

29 lethal consequences. Stress could also alter an animal’s immune system. Stress from capture and 

30 restraint could cause capture myopathy, which occurs when an animal cannot cool itself (Fowler 

31 1978). Capture myopathy is characterized by degeneration and necrosis of striated and cardiac 
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1 muscles and usually develops within 7 to 14 days after significant trauma, stranding, transport, or 

2 capture. 

3 Potential effects from anesthesia used for chemical restraint are described above. Physical restraint of 

4 a pinniped, if not properly executed, may injure or kill an animal (e.g. suffocation under the weight of 

5 a handler). Mechanical restraint methods may pose some risk to pinnipeds. Excessive pressure is 

6 possible using squeeze cages, which may cause trauma or interfere with adequate ventilation. 

7 Restraint boards may use a hinged guillotine to secure an animal’s neck, which could obstruct the 

8 airway (Gulland et al. 2001). 

9 During health assessments animals could become entangled in the capture net, which may result in 

10 injuries or death. Animals may become stressed during handling and restraint. Signs of stress include 

11 reduced respiration, prolonged struggling while being held, and arching. During a health assessment 

12 study in St. Joseph Bay, FL (July 2006), a bottlenose dolphin became entangled deep in capture net 

13 and was found dead during the extrication of other dolphins from the net. Incidental takes of non14 target animals, including USFWS species, are possible during capture activities. Animals may be 

15 accidentally captured in the net and could also become entangled in the net, which may result in 

16 injuries or death. 

17 Tagging/Attachment of Scientific Instruments- Cetaceans. During research activities, tags will not 

18 be attached to large cetacean calves less than six months of age or females accompanying such calves. 

19 For small cetaceans, no tagging will occur on calves less than one year of age and mothers 

20 accompanying these animals would not specifically be targeted. However, they may be tagged if 

21 accidentally captured during health assessments. Tagging would include reactions to the close 

22 approach and the physical attachment of the tag. Reactions to close approaches are described above. 

23 Free-swimming cetaceans often react when hit by tags delivered by remote devices, such as tagging 

24 guns and crossbows. Cetaceans may also react when tags miss the animal and hit the water nearby. 

25 In most cases, the reactions of the remotely tagged animal and non-target animals last little more than 

26 a few minutes, after which behavior appears to return to normal (Watkins and Tyack 1991, Goodyear 

27 1993, Hooker et al. 2001). The physical presence of a tag may lead to an alteration in the normal 

28 behavior of tagged animals, including a temporary disruption of feeding or mating activities. The 

29 hydrodynamic drag created by the presence of the tag on the animal should not cause an adverse 

30 impact. The proportion of the hydrodynamic drag from the tag package to the animal’s size and 

31 weight is such that the energetic demand on the animal would likely be insignificant. Potential 

32 adverse effects would be minimized by using the smallest possible instrument package and the 
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1 smallest spear tip practicable. Therefore, animal disturbance would only occur during the close 

2 approach and the moment of attachment. 

3 Suction cup tagging procedures have been analyzed by NMFS PR1 in several environmental 

4 assessments (EAs) and biological opinions, where findings resulted in no significant impact on the 

5 animals (NMFS 2004). The possibility of injury to an animal comes from the remote risk of the 

6 suction cup landing in or striking a sensitive part of the animal, such as the eye, mouth, or blowhole. 

7 However, given the skills of the experienced researchers, this risk would be minimal or non-existent. 

8 The non-invasive nature of suction cup tags eliminates the threat of infection, but not inflammation. 

9 The suction cup would not remain attached to the whale for any significant length of time (typically 

10 not longer than 48 hours), and likely releases within a few hours. The animal can easily dislodge the 

11 tag by rolling, breaching, or rubbing. An animal could sustain injuries while trying to remove the tag 

12 by rubbing against the sea floor or other animals. The tag may migrate along the skin of the animal 

13 but would not cover the blowhole, as drag would move it away from the blowhole. The ease and 

14 speed with which some animals can remove a tag indicates that it is unlikely that an animal would 

15 endure long-term stress from the attachment. Vessel strikes pose a risk with suction cup tagging, as 

16 the animal must be followed for the duration of attachment. Vessels would be close to animals and 

17 may strike both target and non-target animals. 

18 Implantable tags used on cetaceans have a greater potential for disturbance in application and would 

19 be more invasive that suction cup tags. Implantable tags typically penetrate the surface of the blubber 

20 layer. Tags generally work their way out of the blubber after weeks or months, but some new satellite 

21 tags may remain implanted for over a year (Mate et al. 2007). Disturbance of the animal would 

22 mainly occur during the close approach and attachment of the tag. Responses often seen include head 

23 lifts, fluke lifts, exaggerated fluke beats on diving, quick dives, or increased swimming speeds. Other 

24 observed responses include evasive swimming behavior, fluke slaps, head lunges, and decreased 

25 surfacing rates. Observations after tagging have shown that responses are short-term (Mate et al. 

26 2007). These responses would not likely injure individuals. The implanted tag would not be 

27 expected to alter the behavior of the whale, particularly with regard to feeding, reproduction, or 

28 migratory behavior. Potential adverse effects are minimized by using the smallest possible 

29 instrument package, a smaller spear tip to minimize penetration into the blubber, and minimizing the 

30 velocity of the package at impact. Inflammation would be expected to occur after tag implantation 

31 and infection would be possible. There would be a low potential for an abscess or septicemia to occur 

32 after implantation. Post-tagging swelling or indentations may occur after the tags are lost, extruded, 
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1 or migrate out. However, there is no evidence that these swellings are signs of infection of the 

2 epidermis or poor health (NMFS 2006). A NMFS PR1 EA (NMFS 2006) states that past research 

3 and permit annual reports have shown that the chance of infection from the break in the epidermis 

4 from an implantable tag is likely to be extremely low and insignificant. 

5 During health assessment captures, animals would be tagged with either a roto-tag or radio tag on the 

6 trailing edge of the dorsal fin. No tagging would occur on young of the year animals. Mothers 

7 accompanying these animals would not specifically be targeted. However, they may be tagged if 

8 accidentally captured so that they may be monitored and/or more readily identified and avoided for 

9 future net sets. The attachment of the roto-tag or radio tag would not be considered significant, as 

10 pain would only last during the application, and local anesthesia may be used. Little tissue damage to 

11 the trailing edge of the dorsal fin would occur when the tag is released. 

12 For saddle tags, the saddle will be raised off the surface of the dorsal fin by inserting foam washers on 

13 the pins between the skin and saddle. This will allow for water flow and heat exchange to occur, 

14 minimizing any effects from placement on the dorsal fin. Spider tags could be ripped out of the 

15 blubber, causing pain and potential infection 

16 Tagging/Attachment of Scientific Instruments- Pinnipeds. Tagging of pinnipeds would cause 

17 temporary stress during capture and restraint to attach or implant the tag. Invasive tags would cause 

18 temporary pain during attachment or implantation. Animal movement may prolong or prevent 

19 healing of flipper tags by producing repetitive stress on the wound. Infection of the wound site would 

20 be possible. The tag may pull out of the flipper during swimming or moving on a rookery or haul-out 

21 site. The site where the tag was could become infected. There is no quantitative information on the 

22 rate of infection caused by flipper tagging (NMFS 2004). 

23 Effects associated with implanted tags may include excessive tissue reaction, infection, and 

24 subsequent rejection of implanted materials. Elephant seals had short reactions to PIT tag implants 

25 and there were no external signs of tissue reaction (Galimberti et al. 2000). For LHX tags, pain 

26 would not occur during surgery, as animals would be anesthetized. Animals may have post-operative 

27 pain and discomfort at the incision site. Animals would be held in captive observation for a period of 

28 time (6 to 10 weeks) to ensure proper wound healing and the absence of complications. If necessary, 

29 animals may be treated with appropriate antibiotics and/or analgesics if an infection or pain occurs. 

30 LHX tags have been used in sea otters for over 20 years, and the typical reactions, both behaviorally 
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1 and physically, to the tag are innocuous (Lander et al. 2001). LHX tags were implanted into 

2 rehabilitated California sea lions with no short- or long-term effects noted (Horning and Hill 2005). 

3 Attachment of scientific instruments to pinnipeds may have both short- and long-term adverse effects, 

4 in addition to the effects of capture and restraint. Possible short-term impacts can include a reduction 

5 in foraging activity or an increase in grooming, at the expense of other behaviors (Kenward 1987). 

6 These types of impacts would likely be present after most tagging events and may be as much a 

7 delayed result of the capture and handling as of the tag’s presence. Some pinnipeds fitted with 

8 crittercams reacted during deployment (tagging) and for a short period after deployment. Few 

9 pinnipeds exhibited curiosity about the crittercam or had aggressive reactions toward it for short 

10 periods (Marshall 1998). The hydrodynamic drag created by the instrument could exert an additional 

11 energetic demand on an animal. Over time, this drag may result in reduced foraging success, 

12 increased metabolic load, and stress to the animal. 

13 The attachments of instruments to the hair with epoxy should not cause pain if done properly. 

14 However, it may result in discomfort if the placement of the instrument causes pulling of the hair or 

15 skin during animal movement. In addition, if the ratio of resin and hardener is not correctly 

16 measured, the resulting heat-producing reaction could burn the animal’s skin and pelage (Lander et al. 

17 2001). Both the resin and hardener could cause skin irritation, resulting in itching, rashes, hives, and 

18 dermatitis. The instrument could be knocked or torn off, pulling out hair and possibly some of the 

19 underlying skin, which would then be open to infection. 

20 Marking. Freeze branding may cause little or momentary pain to cetaceans during application, which 

21 would require 15-20 seconds per brand (typically six brands per animal). Initial discomfort or pain 

22 would be relieved by the appropriate anesthetic or analgesic. Discomfort may persist for some time 

23 after the procedure, but is expected to be minor. Potential discomfort or pain would be relieved by 

24 the appropriate anesthetic or analgesic. Therefore, impacts would be considered negligible and not 

25 significant. 

26 Marking pinnipeds with paint applied remotely using a paint gun may stun an animal and cause 

27 momentary stress and a startle reaction. If the target animal is hit or missed, other non-target animals 

28 may be temporarily disturbed. Capturing and restraining animals for marking with paint, bleach, or 

29 dye would likely involve more stress than remote marking and may cause incidental disturbance of 

30 nearby animals. A pinniped may also be marked by gluing a tag to their fur. The epoxy could cause 

31 burns, skin irritation, or an allergic reaction. Infection would be possible if the tag was torn off. 
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1 Biopsy Sampling. The effects of close approaches needed to conduct biopsy sampling are discussed 

2 above. A careful approach generally elicits, at most, a minimal and short-lived response from whales; 

3 even those subjected to invasive biopsy procedures (NMFS 1992). A NMFS PR1 EA (NMFS 2004) 

4 concluded that, based on existing data and published research, biopsy sampling on large cetaceans 

5 (via crossbow, compound bow, dart guns, or pole spears) would not have long-term adverse effects 

6 on the target species. Published research has shown that short-term effects of biopsy darting on 

7 cetaceans would be startling or momentarily painful to the animal. No evidence of infection at the 

8 sight of penetration or elsewhere has been seen among whales resighted in days following biopsy 

9 sampling (NMFS 1992). 

10 Minke, fin, blue, and humpback whales showed no behavioral reactions to about 45 percent of 

11 successful biopsies, taken with punch-type tips fired from crossbows (Gauthier and Sears 1999). 

12 Behavioral responses in the remainder of the biopsies ranged from tail flicks, hard tail flicks, 

13 submerging below the water surface, or some combination of these responses. Most individuals of 

14 these species resumed their normal behavior within a few minutes of the sample collection. A study 

15 by Clapham et al. (1993) noted that studies on biopsy procedures showed no evidence of short- or 

16 long-term significant impacts on cetaceans. 

17 Surgical biopsy sampling of epidermis and blubber also occur during health assessment captures. 

18 Animals may exhibit signs of stress due to capture and restraint, as discussed above. Animals may 

19 experience momentary pain during the administration of local anesthesia. In rare occurrences, the 

20 biopsied area may become infected. Animals may have some soreness or pain with healing, but other 

21 adverse impacts would not be expected from blubber biopsies (Wells et al. 2005). 

22 Effects of skin and blubber biopsy samples on pinnipeds would include the effects of the capture and 

23 restraint necessary for obtaining these samples are described above. In addition, there would be the 

24 potential for an infection after any of these procedures, given the unsanitary environment of 

25 rookeries. Healthy animals should be able to heal and recover from a properly performed procedure. 

26 Animals with compromised immune systems may develop major complications. The procedures may 

27 also cause more than momentary pain. 

28 Blood Sampling. The risks of blood collection would be largely incidental to capture and restraint. 

29 Multiple attempts to obtain a blood sample would not only be stressful and cause some degree of 

30 pain; they may result in damage to the vein, clotting, and an abscess. Removing a volume of blood 
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1 too large relative to the animal’s mass and ability to replace the amount can result in fatigue, anemia, 

2 weakened immunity, and problems with clotting. 

3 Breath Sampling. Breath sampling activities on free-swimming cetaceans would include close 

4 approaches by vessels. Impacts from close approaches are described above. The use of the extended 

5 pole and the quick physical contact of the vacuum cylinder may affect an animal. The reaction of 

6 cetaceans to physical contact for breath sampling has not been adequately studied. However, the 

7 contact of the apparatus on animals is very brief, lasting only a few seconds. This physical contact is 

8 not likely to disrupt the behavior of marine mammals and would not have a significant effect on an 

9 individual. 

10 Ultrasound Sampling. Ultrasound sampling activities on free-swimming cetaceans would include 

11 close approaches by vessels. Impacts from close approaches are described above. The use of the 

12 extended pole and the quick physical contact of the ultrasound device may affect an animal. The 

13 reaction of cetaceans to physical contact for ultrasound sampling has not been adequately studied. 

14 However, the contact of the apparatus on animals is very brief, lasting only a few seconds. This 

15 physical contact is not likely to disrupt the behavior of marine mammals and would not have a 

16 significant effect on an individual. Ultrasound sampling may occur on animals captured for other 

17 research. Impacts from capture and restraint activities are described above. Cetaceans may be 

18 sampled out of the water and improper body support could compromise cardiac and respiratory 

19 functions (Haulena and Heath 2001). Animals may overheat in direct sun and heat without protection 

20 and body surfaces may be exposed to the drying effects of air. The external ultrasound procedure 

21 itself would pose minimal to no risk of injury to an animal. Internal ultrasound procedures pose the 

22 risks of infection and perforation. 

23 Tooth Extraction. Potential adverse effects from tooth extraction relate to the risks of capture, 

24 restraint, anesthesia, and the possibility of infection following the extraction. The procedure may 

25 result in more than momentary pain, which could temporarily interfere with foraging. 

26 Other Sampling. Other sampling that could occur includes the collection of feces, swabs, sloughed 

27 skin, urine, and other bodily fluids. The close approach of free-swimming cetaceans to collect feces 

28 and sloughed skin would have a minor impact on the animals. The collection of pinniped feces may 

29 disturb animals on haul-out sites or rookeries. Animals may rapidly depart the area, which could 

30 result in injury or death. Skin swabs, feces, urine, and other bodily fluids may be collected from 

31 animals during health assessments. Potential adverse effects from this sampling would likely result 
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1 from capture and restraint and not from sampling itself. Efforts would be made to reduce the animal 

2 holding time. 

3 Hair, Nails, and Vibrissae Sampling. Clipping hair, nails, and whiskers would not likely result in 

4 pain. The effects on the animal from clipping are probably incidental to the effects of capture and 

5 restraint. Pulling a whisker may cause more than momentary pain, due to the highly sensitive nature 

6 of the snout and because the hair bulb is surrounded by blood and neurons. 

7 Administration of Drugs and Euthanasia. Delivery of anesthesia or sedation in marine mammals, 

8 especially pinnipeds, can be complicated by their anatomical and physiological specializations to life 

9 in the marine environment. Determining the proper dose is dependent on a fairly accurate assessment 

10 of the animal’s weight and condition. Miscalculation of an animal’s weight could lead to an 

11 overdose, which can have lethal consequences (Fowler 1986). Anesthesia or sedation may activate 

12 the dive reflex, which would include breath holding, slowing of the heart rate, and the pooling of 

13 blood from peripheral vessels. Phocids that have died as a result of anesthesia exhibited signs of 

14 bradycardia, tachycardia, hypoventilation, cyanosis, hyperthermia, and decreased peripheral perfusion 

15 (Haulena and Heath 2001). Other drugs that may be administered include antibiotics, antifungals, and 

16 analgesics. Potential adverse effects from all drugs include drug interactions, incorrect drug dosages, 

17 side effects, injuries, and death. Effects vary according to drug, dosage, animal, and method of 

18 administration. 

19 Chemical euthanasia may be the most humane method available for marine mammal situations. 

20 Euthanasia may occur with an overdose of sedatives and anesthetics or with euthanasia drugs. Some 

21 euthanasia agents may cause hyperexcitability or violent reactions in animals. Intraperitoneal 

22 administration of a euthanasia solution may cause effects due to differential absorption, leading to the 

23 prolonged onset of action. It may also cause irritation in the surrounding tissues (Greer et al. 2001). 

24 Improper chemical euthanasia agents or methods of delivery may prolong the pain and suffering of an 

25 animal. 

26 The correct use of ballistics to euthanize or humanely kill an animal would cause instantaneous 

27 unconsciousness, followed by respiratory and cardiac arrest or vice versa. Improper uses may not 

28 cause unconsciousness before death and would not be considered humane. During mass strandings, 

29 the use of ballistics may stress and exacerbate fear in the surviving animals, if they die in the vicinity. 

30 The use of ballistics and explosives require expertise for proper placement. Incorrect charge 
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1 placement may not cause instantaneous unconsciousness and may cause tissue destruction (Greer et 

2 al. 2001). 

3 Exsanguination may occur when no other options are available, especially in cases of large whales 

4 after sedation with analgesics or anesthesia. It requires expertise in anatomical knowledge of the 

5 head and cervical spine, or the location and approaches to the heart. Prolonged pain and suffering 

6 would occur if done incorrectly. Exsanguination should never be done on a whale that was conscious 

7 and responsive (Geraci and Lounsbury 2005). 

8 Auditory Brainstem Response (ABR)/Auditory Evoked Potential (AEP). Potential adverse effects 

9 from ABR and AEP procedures would be as a result of capture, restraint, and holding described 

10 above. The maximum sound levels presented would be lower than sound levels produced by animal 

11 whistles and echolocation clicks. Sounds may be quieter than those animals are normally exposed to 

12 on a daily basis. Therefore, impacts from the procedures themselves would not be considered 

13 significant. Short-term impacts, including inflammation and hyperemia, would be expected from the 

14 suction cups used to attach electrodes to the animal. 

15 Diagnostic Testing and Analysis of Specimens. Diagnostic testing and the analysis of specimens 

16 would have no impact on marine mammals. Specimens would be archived in the NMMTB or other 

17 authorized laboratory and would not have any adverse impacts. 

18 Import/Export of Marine Mammals or Marine Mammal Parts. Import and export of specimens 

19 would not have an impact on marine mammals. All specimens would be collected legally in the U.S. 

20 or other foreign countries and meet the other conditions required by the MMPA, and may be subject 

21 to additional requirements and evaluation under the Animal Welfare Act. Potential adverse effects of 

22 importing or exporting marine mammals in rehabilitation would be the result of restraint and 

23 transport. Handling, lifting, and moving an animal could cause injuries. Cetacean flippers may be 

24 crushed or overheat if stretchers do not have openings for them. Creases or seems may press into the 

25 skin, causing discomfort and possible injury. Transport of animals could cause stress or injuries to an 

26 animal. Depending on the mode of transportation, animals may overheat in direct sun and heat 

27 without protection. Animals may develop hypothermia and frostbite if transport occurs during 

28 freezing temperatures. Cetaceans may be exposed to the drying effects of air. Animals may also be 

29 knocked around in the vehicle or vessel or inhale exhaust fumes. Improper transport of cetaceans 

30 may cause abrasions, pressure necrosis, thermoregulatory problems, and respiratory problems. 

31 Cetaceans transported on airplanes are susceptible to the effects of high-altitude sickness. Most 
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1 impacts during transport would be minor and temporary and would end once the animal reached its 

2 destination. 

3 The impacts of restraint and transport would also apply to import and export of permanently captive 

4 marine mammals (for instance, from a foreign public display facility) for health research purposes 

5 under the ESA/MMPA permit. However, the care and handling of captive animals falls under the 

6 purview of the USDA/APHIS. Any import/export activities for captive marine mammals would meet 

7 the conditions for import or export under the MMPA and would be subject to additional requirements 

8 and evaluation under the Animal Welfare Act. 

9 4.2.6.3 Alternative F3- Preferred Alternative 

10 Under Alternative F3, the new ESA/MMPA permit would be issued to include current and future 

11 biomonitoring and research activities. Effects on biological resources from Alternative F3 would be 

12 the same as those described under Alternative F2, with some exceptions for new research activities. 

13 Passive Acoustic Recording. Passive acoustic recording would not have an adverse effect on marine 

14 mammals. The actual presence of the hydrophone in the water would not be expected to have any 

15 impact on marine mammals. A NMFS EA (NMFS 2004) noted that, on some occasions, researchers 

16 have noted instances of animals investigating the hydrophone. However there is no known 

17 documentation of the presence of a hydrophone, or a similar recording device, resulting in any 

18 adverse impact. 

19 Active Acoustic Playbacks. Active acoustic playbacks would involve close approaches by one or 

20 more vessels and would have negligible adverse behavioral impacts on marine mammals, as 

21 described in Section 4.2.6.2. The source levels of the sounds produced under the proposed activities 

22 would be sufficiently low and produced at a large enough distance from the animal (minimum 100 m) 

23 to not result in levels that would be painful or overly disruptive to the animals. Previous tests indicate 

24 that sounds produced by these proposed playback equipment would be less powerful and attenuate 

25 more rapidly than other anthropogenic sources in the action area (i.e. cruise ships, fishing vessels, and 

26 large pleasure craft) (NMFS 2004). Incidental harassment of non-target animals (including USFWS 

27 species) is not likely, as the source levels of the sounds would be sufficiently low. 

28 Cognitive Assessment of Sea Lions in Rehabilitation Suffering from Domoic Acid Intoxication. 

29 All methods used during the assessment will be low-impact and non-invasive, and no immediate or 

30 residual negative impacts on the animals are expected as a result of their participation in the study. 
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1 However, mortality rates are high for domoic acid exposed animals, so it is likely that a proportion of 

2 the subjects will die unpredictably during the course of the study. Based on the results of a previous 

3 3-year study published in Goldstein et al. (2008) and in Zabka et al. (in press), it is expected that 

4 animals suffering from long-term effects of domoic acid will eventually die up to two years post 

5 exposure if they have extensive cardiac or hippocampal lesions that can result in cardiac conduction 

6 defects or seizures. Therefore, it is possible that as many as 50 sea lions may die during the cognitive 

7 assessment procedures as a result of permanent lesions due to domoic acid intoxication. 

8 4.3 Water and Sediment Quality 

9 This section evaluates the potential impacts on water and sediment quality as a result of the 

10 alternatives. Impacts on water and sediment quality are evaluated in context and intensity on a wide 

11 geographic scale. Therefore, while more significant impacts may occur in localized areas, the overall 

12 impact on the watershed, beach, coastline, ocean, etc. would be considered minor. 

13 4.3.1 Stranding Agreements and Response Alternatives 

14 4.3.1.1 Alternative A1- No Action 

15 Under Alternative A1 stranding response from current SA holders would end once all agreements 

16 have expired. No effects on water and sediment quality would be expected to occur under Alternative 

17 A1, as stranding response activities would end. 

18 4.3.1.2 Alternative A2- Status Quo 

19 Under Alternative A2, the current SAs would be renewed and current stranding response activities 

20 would continue without the issuance of Final SA criteria. Minor, short-term adverse effects on water 

21 and sediment quality could occur under Alternative A2. Equipment used for transport could leak oil 

22 or other materials into sand and nearshore waters. This would likely be localized and flushed out 

23 and/or diluted rapidly, causing a minor impact. Tissue, blood, and other body fluids may contain 

24 euthanasia solution, other drugs, POPs, toxic metals, pathogens, and/or biotoxins. Chemical residues 

25 from euthanasia solution and other drugs persist in the carcass at different concentrations and for 

26 different amounts of time. They would not likely create an environmental hazard, as they would be 

27 broken down quickly and would not persist in the surrounding environment. Contaminants would 

28 also be localized and flushed out of the sand and groundwater by the tides and/or precipitation. Any 

29 contaminants entering the nearshore waters would be diluted quickly by the currents, and impacts 

30 would be minor and temporary. 
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1 Animals may also contain chemical residues from substances administered by stranding response 

2 personnel, including chemical euthanasia solution and sedatives. If the animal is a rehabilitated 

3 animal that has restranded, it may also contain antibiotics, antifungals, and other medicine. These 

4 chemicals persist in the animal at different concentrations and for different amounts of time. They 

5 would not likely create an environmental hazard, as they would be broken down quickly and would 

6 not persist in the surrounding environment. 

7 4.3.1.3 Alternative A3 

8 Under Alternative A3, SAs would be issued to any applicants after review, the new SA template 

9 would not be utilized, and the Final SA criteria would not be issued. Effects on water and sediment 

10 quality from stranding response activities under Alternative A3 would be the same as those described 

11 under Alternative A2. 

12 4.3.1.4 Alternative A4- Preferred Alternative 

13 Under Alternative A4, the Final SA criteria and the new SA template would be implemented and 

14 current and future stranding response activities would occur. Effects on water and sediment quality 

15 from stranding response activities under Alternative A4 would be the same as those described under 

16 Alternative A2. 

17 4.3.1.5 Alternative A5 

18 Under Alternative A5, the Final SA criteria and the new SA template would be implemented and 

19 response to threatened, endangered, or rare animals would be required. Effects on water and 

20 sediment quality from stranding response activities under Alternative A5 would be the same as those 

21 described under Alternative A2. 

22 4.3.2 Carcass Disposal Alternatives 

23 4.3.2.1 Alternative B1- No Action 

24 Under Alternative B1, no carcass disposal would occur and carcasses would remain on the beach to 

25 naturally decompose. Carcasses left on the beach to naturally decompose would not cause an impact, 

26 unless the animal contained contaminants. Body fluids may contain POPs, toxic metals, pathogens, 

27 and/or biotoxins could seep into the sand beneath the animal or leach into groundwater and flow into 

28 nearshore waters. If contaminants enter groundwater, they would likely be flushed out quickly by 

29 tidewater and/or precipitation. The impact on water quality would likely be temporary and minor. 
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1 Sediment quality would not likely be impacted by contaminants, as they would be localized and 

2 flushed out or diluted before they could adhere to the substrate. 

3 4.3.2.2 Alternative B2- Status Quo 

4 Under Alternative B2, current methods of carcass disposal would continue. Potential effects depend 

5 on the method of carcass disposal and if the carcass was toxic from the use of euthanasia solution. 

6 Carcasses left on the beach to naturally decompose would not cause an impact, unless the animal had 

7 been chemically euthanized or contains contaminants. The evaluation of the potential toxicological 

8 environmental hazards posed by a decomposing carcass cannot be determined at this time (see 

9 Appendix J). Additionally, the types and levels of contaminants in a carcass are generally not known 

10 at the time of disposal because of the time delay in processing analytical lab tests. However, the 

11 remote potential does exist for decay products of carcasses to be released into the surrounding 

12 environment or recycled into the food web, with subsequent negative impacts. Chemical residues 

13 from euthanasia solution and other drugs persist in the carcass at different concentrations and for 

14 different amounts of time. They would not likely create an environmental hazard, as they would break 

15 down quickly and would not persist in the surrounding environment. Body fluids containing POPs, 

16 toxic metals, pathogens, and/or biotoxins could seep into the sand beneath the animal or leach into 

17 groundwater and flow into nearshore waters. If contaminants enter groundwater, they would likely be 

18 localized and flushed out quickly by tidewater and/or precipitation. Higher concentrations of 

19 contaminants may occur in nearshore waters down site from the carcass. These concentrations would 

20 be diluted and flushed out by the currents. The amount of time for contaminants to flush out of 

21 groundwater would depend upon the amount of precipitation, tides, and the permeability of the 

22 sand/sediment. The size and number of carcasses would also factor into the amount of time for 

23 contaminants to disperse. The impact on water quality would likely be localized, temporary, and 

24 minor. Sediment quality would not likely be impacted by contaminants, as they would be flushed out 

25 or diluted before they could adhere to the substrate. 

26 Burial of carcasses could increase erosion, but this would be a negligible impact. The burial site 

27 would only be disturbed for a short-period of time and would be refilled with sand to match the 

28 surrounding ground level. Burial does not inactivate all pathogens in the carcass. Some carcasses 

29 may contain POPs, toxic metals, pathogens, and/or biotoxins; however the specific types and levels of 

30 contaminants are typically not known at the time of burial. As these carcasses decay, body fluids may 

31 leach into the sand and groundwater, potentially impacting the adjacent coastal waters and sediments. 

32 As described above, contaminants would be flushed out of groundwater and diluted in nearshore 
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1 waters by the currents. Carcasses containing euthanasia solution or other drugs would not likely 

2 persist in the environment. Impacts to water and sediment quality would be temporary and minor. 

3 Disposal of carcasses at sea may negatively impact water and sediment quality. Carcasses of 

4 euthanized animals could release POPs, toxic metals, pathogens, and/or biotoxins into the water or 

5 food web during decomposition. However, the impact would be minor as the contaminants would 

6 dilute rapidly in the water. The material used to sink the carcass may have an adverse effect, if it 

7 could be considered a contaminant. However, Jersey (concrete) barriers would generally be used to 

8 sink a carcass and these would have no impact on water or sediment quality. Transport of the carcass 

9 offsite could temporarily increase erosion, due to the use of heavy equipment. This would be a 

10 negligible impact as equipment would only be used for a short time period (hours). Spills of 

11 hazardous materials or wastes from transport vessels could impact water and sediment quality. 

12 Impacts would be considered minor to major, depending on the material, size of spill, location, and/or 

13 vicinity of these resources. Some materials could be diluted quickly by currents, causing localized, 

14 temporary impacts. Other materials could linger in the water column or adhere to sediment particles, 

15 causing slightly longer but still localized impacts. 

16 Heavy equipment or vehicles may be necessary to transport a carcass off-site. Equipment used to 

17 transport animals could leak oil or other materials into sand and nearshore waters during operations. 

18 These would likely be small amounts that would be localized, flushed out and/or diluted rapidly, 

19 causing a minor, short-term impact. Other materials could linger in the water column or adhere to 

20 sediment particles, causing slightly longer but still localized impacts. 

21 Burial in a landfill would not create any negative impacts for non-toxic carcasses. If carcasses are 

22 known or assumed (based upon test results or prior knowledge of the species) to have contaminant 

23 levels that meet or exceed the local definition of hazardous waste, they would be taken to a hazardous 

24 waste landfill for proper disposal. Carcasses may be taken to a licensed rendering or incineration 

25 facility. Because the landfill, rendering, or incineration facilities have been previously licensed, all 

26 environmental impacts from these facilities have already been considered. Any impacts from these 

27 activities would be covered by the individual rendering or incinerating facility and their permits, not 

28 the MMHSRP or stranding network members. 

29 4.3.2.3 Alternative B3- Preferred Alternative 

30 Under Alternative B3, current methods of carcass disposal would continue with a recommendation to 

31 transport chemically euthanized animal carcasses off-site. The effects on water and sediment quality 
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1 under Alternative B3 would be the same as those described under Alternative B2. However, under 

2 Alternative B3, modifications may be made to carcass disposal activities. Currently, the potential 

3 toxicological environmental hazards posed by a decomposing carcass are not known. If and when 

4 this information becomes available, additional precautions (e.g., removal of certain species carcasses 

5 from beaches) would be implemented, if necessary. These modifications would have a beneficial 

6 impact on water and sediment quality. 

7 Composting may be added as a disposal method after on-going research is completed. By-products 

8 and finished products from composting a carcass would have little or no adverse effects on water and 

9 sediment quality or the surrounding environment (Mukhtar et al. 2004). Temperatures during the 

10 composting process are high enough to kill pathogens and breakdown contaminants and euthanasia 

11 solution (Geraci and Lounsbury 2005). 

12 4.3.3 Rehabilitation Activities Alternatives 

13 4.3.3.1 Alternative C1- No Action 

14 Under Alternative C1, current SAs would expire, stranding response would end, and animals would 

15 not be taken into rehabilitation. No effects on water or sediment quality would be expected to occur 

16 under Alternative C1. Rehabilitation would no longer occur and therefore potential risks to water and 

17 sediment quality would be removed. 

18 4.3.3.2 Alternative C2- Status Quo 

19 Under Alternative C2, current rehabilitation activities would continue, but the final Rehabilitation 

20 Facility Standards would not be implemented. Minor adverse effects could occur under Alternative 

21 C2. Rehabilitation facilities that discharge directly to surface waters would have the required 

22 National Pollutant Discharge Elimination System (NPDES), state, and local permits for facility 

23 discharges. Any wastewater effluent discharged to a publicly owned treatment works (POTWs) 

24 would be required to meet municipal wastewater treatment standards and have any necessary effluent 

25 discharge permits under the Clean Water Act. Impacts from permitted discharges would already be 

26 accounted for under the respective Federal, state, and/or local regulations. Facilities discharging to 

27 POTWs would have a pretreatment plan in place if necessary, as POTWs do not remove toxic 

28 organics or metals. 

29 Net pens could pose minimal adverse impacts to water quality because they are open to ocean and bay 

30 waters. Water and sediment near the pen would be exposed to any medicines, materials, or 
Marine Mammal Health and Stranding Response Program 

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1 equipment used in rehabilitation. There would also be an increase in pathogen and fecal exposure. 

2 Temporary pools would not have any means to treat effluent. Temporary pools could leak water 

3 containing wastes, pathogens, or other contaminants into the soil and groundwater. Temporary pools 

4 could also contaminate water and sediment when they are emptied, if the water is discharged into 

5 surface waters. 

6 4.3.3.3 Alternative C3- Preferred Alternative 

7 Under Alternative C3, new SAs would be issued, rehabilitation activities would continue, and the 

8 final Rehabilitation Facility Standards would be implemented. Effects on water and sediment quality 

9 from rehabilitation activities under Alternative C3 would be the same as those described under 

10 Alternative C2. However, under this alternative, modification of rehabilitation activities could occur. 

11 Rehabilitation activities may change with improvements in technologies, techniques, and other 

12 aspects of marine mammal medicine. Impacts on water and sediment quality from these new 

13 activities would be similar to, or less than, those currently conducted. The closure of rehabilitation 

14 facilities is also included under modification of activities. The closure of a rehabilitation facility 

15 would eliminate any potential adverse impacts on water and sediment quality 

16 4.3.3.4 Alternative C4 

17 Under Alternative C4, new SAs would be issued, rehabilitation activities would continue, and the 

18 final Rehabilitation Facility Standards would be implemented. Effects on water and sediment quality 

19 from rehabilitation activities under Alternative C4 would be the same as those described under 

20 Alternative C2. 

21 4.3.4 Release of Rehabilitated Animals Alternatives 

22 4.3.4.1 Alternative D1- No Action 

23 Under Alternative D1, current SAs would expire, stranding response and rehabilitation would cease, 

24 and there would be no animals to release. No effects on water or sediment quality would be expected 

25 to occur under Alternative D1. Release of rehabilitated animals would not take place and there would 

26 be no risks to water and sediment quality. 

27 4.3.4.2 Alternative D2- Status Quo 

28 Under Alternative D2, current release activities would continue, adaptive changes to release activities 

29 would not be permitted, and the final Release criteria would not be implemented. Minor, short-term, 
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1 adverse effects on water and sediment quality could occur under Alternative D2. Release of 

2 rehabilitated animals would not intentionally generate any pollutants or disturb sediment. However, 

3 spills of hazardous materials or wastes from release vessels could impact water and sediment quality. 

4 Some materials could be diluted quickly by currents, causing temporary impacts. Other materials 

5 could linger in the water column or adhere to sediment particles, causing slightly longer impacts. 

6 Equipment to transport animals could leak oil or other materials into sand and nearshore waters 

7 during beach releases. These would likely be small amounts that would be localized, flushed out, 

8 and/or diluted rapidly, causing a minor, short-term impact. Other materials could linger in the water 

9 column or adhere to sediment particles, causing slightly longer but still localized impacts. 

10 4.3.4.3 Alternative D3- Preferred Alternative 

11 Under Alternative D3, new SAs would be issued, release activities would continue, adaptive changes 

12 to release activities would be permitted, and the final Release criteria would be implemented. Effects 

13 on water and sediment quality from Alternative D3 would be the same as those described under 

14 Alternative D2. 

15 4.3.5 Disentanglement Alternatives 

16 4.3.5.1 Alternative E1- No Action 

17 Under Alternative E1, there would be no disentanglement network. No effects on water or sediment 

18 quality would be expected to occur under Alternative E1, as disentanglement activities would no 

19 longer occur. 

20 4.3.5.2 Alternative E2- Status Quo 

21 Under Alternative E2, the disentanglement network would continue the current activities with no 

22 modifications or new members added. Minor, short-term, adverse effects water or sediment quality 

23 could occur under Alternative E2. Disentanglement activities would not intentionally generate any 

24 pollutants or disturb sediment. However, spills of hazardous materials or wastes from 

25 disentanglement vessels could impact water and sediment quality. Some materials could be diluted 

26 quickly by currents, causing localized, temporary impacts. Other materials could linger in the water 

27 column or adhere to sediment particles, causing slightly longer but still localized impacts. 
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Final Programmatic Environmental Impact Statement February 2009 

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1 4.3.5.3 Alternative E3- Preferred Alternative 

2 Under Alternative E3, the disentanglement network would continue the current activities on the East 

3 Coast with modifications to the West Coast network. Effects on water or sediment quality from 

4 Alternative E3 would be the same as those described under Alternative E2. 

5 4.3.6 Biomonitoring and Research Activities Alternatives 

6 4.3.6.1 Alternative F1- No Action 

7 Under Alternative F1, biomonitoring and research activities would not occur. No effects on water and 

8 sediment quality would be expected to occur under Alternative F1. Biomonitoring and research 

9 activities would no longer occur and therefore potential risks to water and sediment quality would be 

10 removed. 

11 4.3.6.2 Alternative F2- Status Quo 

12 Under Alternative F2, the new ESA/MMPA permit would continue the current biomonitoring and 

13 research activities. Minor, short-term, adverse effects on water and sediment quality could occur 

14 under Alternative F2. Biomonitoring and research activities would not intentionally generate any 

15 pollutants or disturb sediment. Spills of hazardous materials or wastes from vessels or the loss of 

16 research materials overboard could impact water and sediment quality. Some materials could be 

17 diluted quickly by currents, only causing localized, temporary impacts. Other materials could linger 

18 in the water column or adhere to sediment particles, causing slightly longer but still localized impacts. 

19 Equipment used for beach research activities could leak oil or other materials into sand and nearshore 

20 waters. These would likely be small amounts that would be flushed out and/or diluted rapidly, 

21 causing a minor, short-term impact. 

22 Any hazardous or non-hazardous wastes from laboratories used for diagnostic testing and analyses 

23 would be covered under those laboratories and their hazardous wastes and wastewater permits, not the 

24 MMHSRP. 

25 4.3.6.3 Alternative F3- Preferred Alternative 

26 Under Alternative F3, the new ESA/MMPA permit would be issued to include current and future 

27 biomonitoring and research activities. Effects on water and sediment quality from Alternative F3 

28 would be the same as those described under Alternative F2. 
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Final Programmatic Environmental Impact Statement February 2009 

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1 4.4 Cultural Resources 

2 This section evaluates the potential impacts on cultural resources as a result of the alternatives. 

3 Section 5.4 of this PEIS describes mitigation measures that would be taken to protect cultural 

4 resources under certain alternatives. These mitigation measures include contacting the appropriate 

5 SHPO prior to undertaking actions, such as carcass burial, in areas where there is a potential for 

6 submerged or buried cultural resources to be present. 

7 4.4.1 Stranding Agreements and Response Alternatives 

8 4.4.1.1 Alternative A1- No Action 

9 Under Alternative A1 stranding response from current SA holders would end once all agreements 

10 have expired. No effects on cultural resources would be expected to occur from Alternative A1. 

11 Stranding response activities would end, removing any potential risk to cultural resources. 

12 4.4.1.2 Alternative A2- Status Quo 

13 Under Alternative A2, the current SAs would be renewed and current stranding response activities 

14 would continue without the issuance of Final SA criteria. The use of equipment and vehicles on the 

15 beach, as well as digging, may affect cultural resources buried in sand or dunes. Equipment used in 

16 nearshore waters may affect submerged cultural resources. However, the potential for impact would 

17 be minor, as stranding events are scattered along the entire U.S. coastline. The probability that these 

18 events, and therefore response activities, may be located on a beach or in water containing cultural 

19 resources is small. 

20 Stranding response on Native American/Alaska Native lands would be coordinated with Native 

21 American tribes, Alaska Natives, or other aboriginal peoples to accommodate cultural uses of marine 

22 mammals. Responders would also be sensitive to the fact that tribal cultures often involve 

23 ceremonial, medicinal, or subsistence uses or plants, animals (including marine mammals), and 

24 specific geographic locations. There would not be any effects on Alaska Natives, Native American 

25 tribes, or other aboriginal people’s cultural uses of coastal resources. 

26 4.4.1.3 Alternative A3 

27 Under Alternative A3, SAs would be issued to any applicants after review, the new SA template 

28 would not be utilized, and the Final SA criteria would not be issued. The effects on cultural resources 

29 from Alternative A3 would be the same as those described under Alternative A2. 
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Final Programmatic Environmental Impact Statement February 2009 

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1 4.4.1.4 Alternative A4- Preferred Alternative 

2 Under Alternative A4, the Final SA criteria and the new SA template would be implemented and 

3 current and future stranding response activities would occur. The effects on cultural resources from 

4 Alternative A4 would be the same as those described under Alternative A2. 

5 4.4.1.5 Alternative A5 

6 Under Alternative A5, the Final SA criteria and the new SA template would be implemented and 

7 response to threatened, endangered, or rare animals would be required. The effects on cultural 

8 resources from Alternative A5 would be the same as those described under Alternative A2. 

9 4.4.2 Carcass Disposal Alternatives 

10 4.4.2.1 Alternative B1- No Action 

11 Under Alternative B1, no carcass disposal would occur and carcasses would remain on the beach to 

12 naturally decompose. No effects on cultural resources would be expected to occur from Alternative 

13 B1. Carcass disposal activities would end, removing any potential risk to cultural resources. 

14 4.4.2.2 Alternative B2- Status Quo 

15 Under Alternative B2, current methods of carcass disposal would continue. Minor, adverse effects on 

16 cultural resources could be expected to occur under Alternative B2. Carcass burial could damage 

17 resources located on or beneath the beach. Digging may unearth artifacts and equipment used for 

18 digging could physically impact buried resources. This would negatively impact areas such as the 

19 Pacific Islands area, where many known artifacts and habitation sites are buried on beaches. 

20 Transporting the carcass off-site has the potential to damage resources, as the equipment used could 

21 crush buried resources. However, the potential for impact would be minor, as stranding events are 

22 scattered along the entire U.S. coastline. The probability that these events, and therefore disposal 

23 activities, may be located on a beach or in water containing cultural resources is small. 

24 Carcass disposal on Native American/Alaska Native lands would be coordinated with Native 

25 American tribes, Alaska Natives, or other aboriginal peoples to accommodate cultural uses of marine 

26 mammals. Responders would also be sensitive to the fact that tribal cultures often involve 

27 ceremonial, medicinal, or subsistence uses or plants, animals (including marine mammals), and 

28 specific geographic locations. There would not be any effects on Alaska Natives, Native American 

29 tribes, or other aboriginal people’s cultural uses of coastal resources. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

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1 4.4.2.3 Alternative B3- Preferred Alternative 

2 Under Alternative B3, current methods of carcass disposal would continue with a recommendation to 

3 transport chemically euthanized animal carcasses off-site. The effects on cultural resources from 

4 Alternative B3 would be the same as those described under Alternative B2. 

5 4.4.3 Rehabilitation Activities Alternatives 

6 4.4.3.1 Alternative C1- No Action 

7 Under Alternative C1, current SAs would expire, stranding response would end, and animals would 

8 not be taken into rehabilitation. No effects on cultural resources would be expected to occur under 

9 Alternative C1. Rehabilitation activities would end, removing any potential risk to cultural resources. 

10 4.4.3.2 Alternative C2- Status Quo 

11 Under Alternative C2, current rehabilitation activities would continue, but the final Rehabilitation 

12 Facility Standards would not be implemented. Potential minor, adverse effects on cultural resources 

13 could be expected to occur under Alternative C2. The use of temporary pools could damage cultural 

14 resources, depending on where they are sited. The use of net pens may disturb or damage submerged 

15 cultural resources. 

16 4.4.3.3 Alternative C3- Preferred Alternative 

17 Under Alternative C3, new SAs would be issued, rehabilitation activities would continue, and the 

18 final Rehabilitation Facility Standards would be implemented. The effects on cultural resources from 

19 Alternative C3 would be the same as those described under Alternative C2. 

20 4.4.3.4 Alternative C4 

21 Under Alternative C4, new SAs would be issued, rehabilitation activities would continue, and the 

22 final Rehabilitation Facility Standards would be implemented. The effects on cultural resources from 

23 Alternative C4 would be the same as those described under Alternative C2. 

24 4.4.4 Release of Rehabilitated Animals Alternatives 

25 During the public comment period, particular concerns were raised regarding the release of 

26 rehabilitated ices seals in Alaskan waters. In response to these concerns, which raised issues related 

27 to potential effects on cultural resources for subsistence harvest of ice seals, several of the alternatives 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

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1 would adopt mitigation measures to minimize the potential for disease transmission from rehabilitated 

2 ices seals, as described in Section 5.2.4 of this PEIS. 

3 4.4.4.1 Alternative D1- No Action 

4 

5 Under Alternative D1, current SAs would expire, stranding response and rehabilitation would cease, 

6 and there would be no animals to release. No effects on cultural resources would be expected to occur 

7 from Alternative D1. Release of rehabilitated animals would end, removing any potential risk to 

8 cultural resources. 

9 4.4.4.2 Alternative D2- Status Quo 

10 Under Alternative D2, current release activities would continue, adaptive changes to release activities 

11 would not be permitted, and the final Release criteria would not be implemented. Minor, adverse 

12 effects on cultural resources could be expected to occur from Alternative D2. The use of equipment 

13 and vehicles on the beach during release activities may affect cultural resources buried in sand or 

14 dunes. However, the potential for impact would be minor, as release activities are scattered along the 

15 entire U.S. coastline. The probability that these activities may be located on a beach containing 

16 cultural resources is small. Archaeological studies have not been conducted in most coastal areas. 

17 Release activities conducted at sea would not affect any submerged cultural resources. 

18 4.4.4.3 Alternative D3- Preferred Alternative 

19 Under Alternative D3, new SAs would be issued, release activities would continue, adaptive changes 

20 to release activities would be permitted, and the final Release criteria would be implemented. The 

21 effects on cultural resources from Alternative D3 would be the same as those described under 

22 Alternative D2. 

23 4.4.5 Disentanglement Alternatives 

24 4.4.5.1 Alternative E1- No Action 

25 Under Alternative E1, there would be no disentanglement network. No effects on cultural resources 

26 would be expected to occur from Alternative E1. Disentanglement activities would end, removing 

27 any potential risk to cultural resources. 
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Final Programmatic Environmental Impact Statement February 2009 

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1 4.4.5.2 Alternative E2- Status Quo 

2 Under Alternative E2, the disentanglement network would continue the current activities with no 

3 modifications or new members added. No effects on cultural resources would be expected to occur 

4 from Alternative E2. Disentanglement activities would generally occur in open ocean areas and 

5 would not be near or in contact with any submerged cultural resources. Pinniped disentanglements 

6 may occur on beaches, but impacts to cultural resources would not be expected. 

7 4.4.5.3 Alternative E3- Preferred Alternative 

8 Under Alternative E3, the disentanglement network would continue the current activities on the East 

9 Coast with modifications to the West Coast network. No effects on cultural resources would be 

10 expected to occur from Alternative E3. Disentanglement activities would generally occur in open 

11 ocean areas and would not be near or in contact with any submerged cultural resources. Pinniped 

12 disentanglements may occur on beaches, but impacts to cultural resources would not be expected. 

13 4.4.6 Biomonitoring and Research Activities Alternatives 

14 4.4.6.1 Alternative F1- No Action 

15 Under Alternative F1, biomonitoring and research activities would not occur. No effects on cultural 

16 resources would be expected to occur from Alternative F1. Biomonitoring and research activities 

17 would end, removing any potential risk to cultural resources. 

18 4.4.6.2 Alternative F2- Status Quo 

19 Under Alternative F2, the new ESA/MMPA permit would continue the current biomonitoring and 

20 research activities. Adverse effects on cultural resources would not likely occur from this alternative. 

21 Research activities conducted on beaches could potentially disturb buried resources if vehicles or 

22 other equipment is used. Research activities conducted in the water, such as health assessment 

23 captures, could damage submerged cultural resources. Activities may involve anchoring boats or nets 

24 to the bottom and positioning researchers in the water. Activities in shallow areas could potentially 

25 disturb or come in contact with artifacts and other resources. Research activities in open ocean areas 

26 would not be near or in contact with any submerged cultural resources. However, the potential for 

27 impact would be minor as research activities are scattered along the entire U.S. coastline. The 

28 probability that these activities may be located on a beach or in water containing cultural resources is 

29 small. 
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Final Programmatic Environmental Impact Statement February 2009 

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1 4.4.6.3 Alternative F3- Preferred Alternative 

2 Under Alternative F3, the new ESA/MMPA permit would be issued to include current and future 

3 biomonitoring and research activities. The effects on cultural resources from Alternative F3 would be 

4 the same as those described under Alternative F2. 

5 4.5 Human Health and Safety 

6 This section evaluates the potential impacts on human health and safety as a result of the alternatives. 

7 4.5.1 Stranding Agreements and Response Alternatives 

8 4.5.1.1 Alternative A1- No Action 

9 Under Alternative A1 stranding response from current SA holders would end once all agreements 

10 have expired. Response to all stranded animals, alive or dead, would not occur and animals would be 

11 left on beaches. Without response activities, people would likely approach the animal or carcass 

12 either out of curiosity or in an attempt to help. Animal carcasses and live animals may contain 

13 contaminants or zoonotic diseases that people or domestic animals may come in contact with through 

14 tissues, fluids, bites, or scratches. Live animals may bite, roll, or thrash around, causing physical 

15 injuries to people who attempt to interact with the animals. 

16 Direct, beneficial effects would be expected for stranding response personnel. As response to stranded 

17 animals ends, the safety risks for response personnel would no longer exist. 

18 4.5.1.2 Alternative A2- Status Quo 

19 Under Alternative A2, the current SAs would be renewed and current stranding response activities 

20 would continue without the issuance of Final SA criteria. The general public could be affected if they 

21 approached the carcass or live animal out of curiosity or in an attempt to help. Animal carcasses and 

22 live animals may contain contaminants or zoonotic diseases that people or domestic animals may 

23 come in contact with through tissues or fluids. People may have allergic reactions to animal blubber 

24 and oils. Serious infections may occur from contact with animals. Pathogens encountered may be 

25 antibiotic resistant, making treatment more difficult. Live animals may bite, roll, or thrash around, 

26 causing physical injuries. However, the potential for adverse effects is less under this alternative than 

27 Alternative A1, as responders would be on scene, reducing the ability for the public to come into 

28 contact with an animal. 
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Final Programmatic Environmental Impact Statement February 2009 

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1 Risk to responders would also include contaminants, zoonotic diseases, and physical injuries. 

2 Contaminants, including biotoxins and petroleum products, may produce short-term affects, such as 

3 respiratory problems, lightheadedness, nausea, eye irritation, or skin irritation. Responders may have 

4 allergic reactions to animal blubber and oils. Serious infections may occur from contact with animals. 

5 Pathogens encountered may be antibiotic resistant, making treatment more difficult. Zoonotic 

6 diseases may have short-term affects including swelling, joint pain, skin lesions, and flu-like 

7 symptoms. Long-term effects from zoonotic diseases could occur, especially if they are not 

8 diagnosed properly. Physical injuries may include strains or bruises from moving an animal or from 

9 slips, trips, or falls. Workers may be injured by stepping on broken glass, rusty metal, needles, or 

10 other litter. Workers could become entangled in derelict fishing gear during water responses. 

11 Workers may also come into contact with contaminated debris, including medical wastes and sewage. 

12 Accidental injections or exposure to euthanasia solution could cause adverse effects, depending on 

13 the chemical(s) used. Etorphine can be absorbed through broken skin and mucous membranes (e.g. 

14 eyes, nose, and mouth). Accidental injections of paralytic agents are considered life-threatening 

15 (Greer et al. 2001). Responses in or close to water could result in drowning if proper safety measures 

16 are not taken. Responders in water may come into contact with sharks, jellyfish, rays, and other 

17 venomous fish. 

18 4.5.1.3 Alternative A3 

19 Under Alternative A3, SAs would be issued to any applicants after review, the new SA template 

20 would not be utilized, and the Final SA criteria would not be issued. Effects on human health and 

21 safety from Alternative A3 would be the same as those described under Alternative A2. 

22 4.5.1.4 Alternative A4- Preferred Alternative 

23 Under Alternative A4, the Final SA criteria and the new SA template would be implemented and 

24 current and future stranding response activities would occur. Effects on human health and safety from 

25 Alternative A4 would be similar to those described under Alternative A2. However, the 

26 implementation of SA criteria would ensure that responders are experienced and therefore have the 

27 knowledge to avoid or minimize health and safety risks. 
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Final Programmatic Environmental Impact Statement February 2009 

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1 4.5.1.5 Alternative A5 

2 Under Alternative A5, the Final SA criteria and the new SA template would be implemented and 

3 response to threatened, endangered, or rare animals would be required. Effects on human health and 

4 safety from Alternative A5 would be the same as those described under Alternative A4. 

5 4.5.2 Carcass Disposal Alternatives 

6 4.5.2.1 Alternative B1- No Action 

7 Under Alternative B1, no carcass disposal would occur and carcasses would remain on the beach to 

8 naturally decompose. Carcasses of most stranded animals would be left on beaches and would 

9 naturally decompose (limited carcass disposal may still occur from Federal (not including NMFS), 

10 state, and local agencies authorized under MMPA Section 109(h)). People would likely approach and 

11 touch the carcass out of curiosity. Animal carcasses may contain contaminants or zoonotic diseases 

12 that people may come in contact with through tissues or fluids. Contaminants, including petroleum 

13 products and other hazardous materials, may produce short-term affects, such as respiratory problems, 

14 lightheadedness, nausea, eye irritation, or skin irritation. If disposal activities occur during a Karenia 

15 brevis bloom (a HAB), aerosolized brevetoxins may be inhaled by humans and could cause 

16 respiratory problems, nausea, vomiting, and neurological symptoms. People may have allergic 

17 reactions to animal blubber and oils. Serious infections may occur from contact with carcasses. 

18 Pathogens encountered may be antibiotic resistant, making treatment more difficult. Zoonotic 

19 diseases may have short-term affects including swelling, joint pain, skin lesions, and flu-like 

20 symptoms. Long-term effects from zoonotic diseases could occur, especially if they are not 

21 diagnosed or treated properly. 

22 Contaminated carcasses left on the beach could potentially contaminate the groundwater and/or 

23 nearshore water. Impacts would be minor and temporary, as contaminants in groundwater would 

24 likely be flushed out quickly by tidewater and/or precipitation. Contaminants in nearshore waters 

25 would rapidly be diluted and flushed out by currents. Risks to human health could occur if toxic 

26 carcasses were consumed. 

27 The alternative would have a beneficial effect, as personnel involved in carcass disposal would no 

28 longer be exposed to health and safety risks. 
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1 4.5.2.2 Alternative B2- Status Quo 

2 Under Alternative B2, current methods of carcass disposal would continue. Minor, short-term, 

3 adverse effects on human health and safety would be expected to occur under Alternative B2. 

4 Carcasses of stranded animals may be left to naturally decompose, buried, towed to sea, or 

5 transported off-site to a rendering facility, landfill, or compost facility. Animal carcasses may contain 

6 euthanasia solution, contaminants, or zoonotic diseases that people may come in contact with through 

7 tissues or fluids, if the carcasses are left to naturally decompose. Contaminants, including petroleum 

8 products and other hazardous materials, may produce short-term affects, such as respiratory problems, 

9 lightheadedness, nausea, eye irritation, or skin irritation. If disposal activities occur during a Karenia 

10 brevis bloom (a HAB), aerosolized brevetoxins may be inhaled by humans and could cause 

11 respiratory problems, nausea, vomiting, and neurological symptoms. People may have allergic 

12 reactions to animal blubber and oils. Serious infections may occur from contact with carcasses. 

13 Pathogens encountered may be antibiotic resistant, making treatment more difficult. Zoonotic 

14 diseases may have short-term affects including swelling, joint pain, skin lesions, and flu-like 

15 symptoms. Long-term affects from zoonotic diseases could occur, especially if they are not 

16 diagnosed or treated properly. 

17 Carcasses containing environmental contaminants left on the beach or buried could potentially 

18 contaminate the groundwater and/or nearshore water. Impacts would be minor and temporary, as 

19 contaminants in groundwater would likely be flushed out quickly by tidewater and/or precipitation. 

20 Contaminants in nearshore waters would rapidly be diluted and flushed out by currents. Chemically 

21 euthanized carcasses left on the beach or buried would not likely effect human health. Risks to 

22 human health could occur if toxic or chemically euthanized carcasses were consumed. 

23 Persons involved with the disposal risk physical injuries from using equipment to bury, transport off24 site, or tow the carcass out to sea. Persons could be hit or crushed by equipment or may risk 

25 drowning when towing the carcass out to sea. Carcasses that are disposed in shipping lanes or 

26 resurface could cause vessel accidents. 

27 4.5.2.3 Alternative B3- Preferred Alternative 

28 Under Alternative B3, current methods of carcass disposal would continue with a recommendation to 

29 transport chemically euthanized animal carcasses off-site. Effects on human health and safety under 

30 Alternative B3 would be the same as those described under Alternative B2, with one exception. 

31 Chemically euthanized animal carcasses would not be buried on the beach whenever possible, 
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1 minimizing the risk of humans coming in contact with these carcasses. This would be a beneficial 

2 impact on health and safety. However, carcasses containing environmental contaminants could still be 

3 buried and contaminate the groundwater and/or nearshore water. Impacts would be minor and 

4 temporary, as contaminants in groundwater would likely be flushed out quickly by tidewater and/or 

5 precipitation. Contaminants in nearshore waters would rapidly be diluted and flushed out by currents. 

6 Risks to human health would still exist if toxic carcasses were consumed. 

7 Under this alternative, modifications may be made to carcass disposal activities. Currently, the 

8 potential toxicological environmental hazards posed by a decomposing carcass are not known. If and 

9 when this information becomes available, additional precautions (e.g., removal of certain species 

10 carcasses from beaches) would be implemented, if necessary. These modifications would have a 

11 beneficial impact on human health and would remove the risk of toxic carcasses being consumed. 

12 4.5.3 Rehabilitation Activities Alternatives 

13 4.5.3.1 Alternative C1- No Action 

14 Under Alternative C1, current SAs would expire, stranding response would end, and animals would 

15 not be taken into rehabilitation. A beneficial effect on human health and safety would be expected to 

16 occur from Alternative C1. Rehabilitation of marine mammals would no longer occur and risks to 

17 marine mammal workers would end. 

18 4.5.3.2 Alternative C2- Status Quo 

19 Under Alternative C2, current rehabilitation activities would continue, but the final Rehabilitation 

20 Facility Standards would not be implemented. Minor, short-term, adverse effects on human health 

21 and safety could be expected to occur from under Alternative C2. Animal induced injuries would 

22 include bites or physical injuries from being hit by a fin, tail, or other body part. Working on wet 

23 surfaces may cause bruises, slips, trips, or falls. Drowning is a possibility as work would occur 

24 around or in pools and pens. Physical injuries may occur from the use of other equipment. 

25 Rehabilitation staff may be exposed to contaminants, potential zoonotic pathogens, euthanasia 

26 solution, animal drugs, and chemicals used for sanitation purposes. Contaminants, including 

27 petroleum products and other hazardous materials, may produce short-term affects, such as 

28 respiratory problems, lightheadedness, nausea, eye irritation, or skin irritation. If disposal activities 

29 occur during a Karenia brevis bloom (a HAB), aerosolized brevetoxins may be inhaled by humans 

30 and could cause respiratory problems, nausea, vomiting, and neurological symptoms. Serious 
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1 infections may occur from contact with animals. Pathogens encountered may be antibiotic resistant, 

2 making treatment more difficult. Zoonotic diseases may have short-term affects including swelling, 

3 joint pain, skin lesions, and flu-like symptoms. Long-term affects from zoonotic diseases could 

4 occur, especially if they are not diagnosed properly. 

5 Accidental injections or exposure to euthanasia solution could cause adverse effects, depending on 

6 the chemical(s) used. Etorphine can be absorbed through broken skin and mucous membranes (e.g. 

7 eyes, nose, and mouth). Accidental injections of paralytic agents are considered life-threatening 

8 (Greer et al. 2001). Accidental injections and exposure to other drugs used in animal treatment could 

9 occur and affects would depend upon the drug. Facility personnel may come into contact with 

10 harmful chemicals used for cleaning or maintaining pool water quality. Improperly stored or handled 

11 pool chemicals can be highly reactive and may generate high temperatures, release toxic vapors, or 

12 ignite nearby combustible materials. Reactivity may be triggered by the inadvertent mixing of a pool 

13 chemical with an incompatible material or wetting the chemical with water (EPA 2001). 

14 4.5.3.3 Alternative C3- Preferred Alternative 

15 Under Alternative C3, new SAs would be issued, rehabilitation activities would continue, and the 

16 final Rehabilitation Facility Standards would be implemented. Effects on human health and safety 

17 from Alternative C3 would be the same as those described under Alternative C2, with one exception. 

18 The Rehabilitation Facility Standards would be implemented under Alternative C3, which would have 

19 a beneficial effect on health and safety. While some of these measures may currently occur at 

20 rehabilitation facilities, the standards would ensure that all facilities would be implementing the most 

21 effective safety measures. The standards would require safety plans for the direct handling of all 

22 species seen at the facility. Personnel would be trained to identify potential zoonotic diseases and 

23 prevent their transmission from animal to human. Staff would also be trained to properly handle 

24 contaminated equipment and proper sanitation techniques. Safety equipment such as eye protection, 

25 protective clothing, and eye flushing stations, would be provided. 

26 4.5.3.4 Alternative C4 

27 Under Alternative C4, new SAs would be issued, rehabilitation activities would continue, and the 

28 final Rehabilitation Facility Standards would be implemented. Effects on human health and safety 

29 from Alternative C4 would be the same as those described under Alternative C3. 
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1 4.5.4 Release of Rehabilitated Animals Alternatives 

2 4.5.4.1 Alternative D1- No Action 

3 Under Alternative D1, current SAs would expire, stranding response and rehabilitation would cease, 

4 and there would be no animals to release. A beneficial effect on human health and safety would be 

5 expected from Alternative D1. Release activities would cease and risks to marine mammal workers 

6 would end. 

7 4.5.4.2 Alternative D2- Status Quo 

8 Under Alternative D2, current release activities would continue, adaptive changes to release activities 

9 would not be permitted, and the final Release criteria would not be implemented. Minor, short-term, 

10 adverse effects could be expected from Alternative D2. Physical injuries, such as strains, cuts, and 

11 bruises, may occur while lifting and moving an animal for transport. Injuries from animals, such as 

12 bites or being hit by flukes may occur. Exposure to liquid nitrogen, used for freeze branding, may 

13 occur while pouring liquid nitrogen or coming in contact with the brand. Liquid nitrogen can cause 

14 rapid freezing and tissue damage to skin, eyes, and other exposed body parts. Vessel collisions, fire, 

15 capsizing, running aground, and inclement weather during cetacean release activities can result in 

16 injuries, including bruises, cuts, drowning, and lightning strikes. 

17 4.5.4.3 Alternative D3- Preferred Alternative 

18 Under Alternative D3, new SAs would be issued, release activities would continue, adaptive changes 

19 to release activities would be permitted, and the final Release criteria would be implemented. Effects 

20 on human health and safety from Alternative D3 would be the same as those described under 

21 Alternative D2. 

22 4.5.5 Disentanglement Alternatives 

23 4.5.5.1 Alternative E1- No Action 

24 Under Alternative E1, there would be no disentanglement network. A beneficial effect on marine 

25 mammal responder health and safety would be expected under Alternative E1. Disentanglement 

26 operations would end and responders would no longer be at risk of injury. However, adverse impacts 

27 on public health and safety could occur if individuals attempted to disentangle an animal themselves. 

28 Risks would include serious physical injuries and drowning. 
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1 4.5.5.2 Alternative E2- Status Quo 

2 Under Alternative E2, the disentanglement network would continue the current activities with no 

3 modifications or new members added. Responders put themselves at risk during all disentanglements. 

4 The boat could become entangled in the lines connected to the whale. Animal movements may cause 

5 serious physical injuries, knock a person overboard, or capsize the boat. Drowning is a very real 

6 threat to responders. Responders could also become entangled in restraint lines onboard the boat or 

7 while attempting to cut lines from the animal. Responders could come into contact with drugs used 

8 for the chemical restraint of animals. Under this alternative, no responders would enter the water to 

9 cut lines. 

10 Modifications, including new techniques and tools, are not allowed. Without modifications, hazards 

11 to responders would still occur and could feasibly increase. Human safety risks would also increase 

12 without the implementation of disentanglement guidelines and training prerequisites. Less 

13 experienced individuals would not have the skills and knowledge to avoid or minimize dangerous 

14 situations, putting themselves and others at risk. 

15 Potential adverse effects on public health and safety could occur. Individuals may attempt to 

16 disentangle an animal, putting themselves at risk of serious physical injuries and drowning. 

17 4.5.5.3 Alternative E3- Preferred Alternative 

18 Under Alternative E3, the disentanglement network would continue the current activities on the East 

19 Coast with modifications to the West Coast network. Risks to responders and safety measures would 

20 be the same as those described under Alternative E2. However, there would be less risk under this 

21 alternative, as modifications which could reduce threats to responders, would be allowed. New 

22 techniques and tools could decrease the time necessary for disentanglements, therefore reducing the 

23 time responders are on the water and in contact with animals. New tools, such as cutting instruments, 

24 may reduce the potential for injuries. Modifications of safety measures would also reduce threats to 

25 responders. Implementation of disentanglement guidelines and training prerequisites would increase 

26 the number of experienced responders. Experienced responders would have the skills and knowledge 

27 to avoid or minimize dangerous situations. Even with experienced responders and safety measures, 

28 there would still be potential for adverse effects on human health and safety. 

29 Potential adverse effects on public health and safety could occur. Individuals may attempt to 

30 disentangle an animal, putting themselves at risk of serious physical injuries and drowning. However, 
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1 the public may decide not to interfere if they know there are qualified, experienced, and authorized 

2 individuals to conduct disentanglement activities. This may reduce some of the potential health and 

3 safety impacts. 

4 4.5.6 Biomonitoring and Research Activities Alternatives 

5 4.5.6.1 Alternative F1- No Action 

6 Under Alternative F1, biomonitoring and research activities would not occur. A beneficial effect on 

7 human health and safety would occur under Alternative F1. Biomonitoring and research activities 

8 would cease and risks to researchers would end. 

9 4.5.6.2 Alternative F2- Status Quo 

10 Under Alternative F2, the new ESA/MMPA permit would continue the current biomonitoring and 

11 research activities. Personnel working on sample analyses in laboratories may come into contact with 

12 harmful chemicals. Physical injuries may be sustained from the use of laboratory equipment or sharp 

13 instruments. 

14 All researchers conducting activities outdoors, either on land or vessel, risk sunburn, heat exhaustion, 

15 or heat stroke in hot weather or hypothermia in cold weather. Researchers conducting activities on 

16 pinniped rookeries and haul-out sites risk attacks by the animals. Besides a physical injury, bites or 

17 other contact may expose researchers to zoonotic diseases. 

18 Sampling animals from vessels pose a variety of safety hazards. The use of crossbows, poles, and 

19 other equipment used for tagging and sampling could cause serious physical injuries. Risks would 

20 also include vessel collisions, capsizing, and drowning. Walking on wet boat decks increases the 

21 chance of slips, trips, and falls. 

22 Cetacean capture-release health assessments create many scenarios where human health and safety 

23 may be adversely impacted. Bruises, cuts, drowning, and other physical injuries could occur from 

24 vessel collisions, fire, capsizing, running aground, and inclement weather. Entanglement in the 

25 capture net may lead to cuts, bruises, and drowning. Physical injury may occur if appendages or a 

26 person becomes caught between rafted boats. Exposure to liquid nitrogen, used for freeze branding, 

27 may occur while pouring liquid nitrogen or coming in contact with the brand. Liquid nitrogen can 

28 cause rapid freezing and tissue damage to skin, eyes, and other exposed body parts. Restraint and 

29 handling of the animal may expose personnel to zoonotic diseases. Physical injuries may result if the 
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1 animal thrashes around during restraint and sampling activities. Accidental needle sticks and 

2 exposure to chemicals may occur during the sampling process. Activities in water may expose 

3 individuals to harmful animals, such as venomous rays and skates, sharks, jellyfish, and sea lice. 

4 Shallow environments may have shells and other hard parts that can scrape or cut skin. 

5 4.5.6.3 Alternative F3- Preferred Alternative 

6 Under Alternative F3, the new ESA/MMPA permit would be issued to include current and future 

7 biomonitoring and research activities. Effects on human health and safety from Alternative F3 would 

8 be the same as those described under Alternative F2. 

9 4.6 Socioeconomics 

10 This section evaluates the potential impacts on socioeconomics as a result of the alternatives. 

11 4.6.1 Stranding Agreements and Response Alternatives 

12 4.6.1.1 Alternative A1- No Action 

13 Under Alternative A1 stranding response from current SA holders would end once all agreements 

14 have expired. Moderate, long-term beneficial direct effects to current stranding network members 

15 would be expected to occur under Alternative A1. Allowing SAs to expire would mean that network 

16 members would no longer respond to stranding events, leading to a reduction, if not an elimination, of 

17 costs incurred from response activities. However, businesses or individuals whose only function is 

18 stranding response would be adversely affected. Businesses would close and individuals would lose 

19 their jobs. There may also be minor to moderate indirect adverse effects to those SA holders whose 

20 response and/or rehabilitation activities attract external funding. Federal, state, and local government 

21 agencies authorized under MMPA Section 109(h) would benefit from the absence of private stranding 

22 network members. These agencies would likely compete and receive funding from the Prescott Grant 

23 program to enhance their stranding response programs. 

24 Negligible adverse effects may be borne by accommodations and restaurants adjacent to stranding 

25 sites. The alternative would reduce the occurrences of temporary local beach closures associated with 

26 stranding activities. However, the elimination of SAs would reduce response activities and increase 

27 the instances of dead marine mammals left to decompose on the beach (either by not removing 

28 carcasses and/or the increased likelihood of stranded animals being left to die). Carcasses may be 

29 removed by other Federal, state, or local governments authorized under the MMPA Section 109(h). 
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1 Decomposing carcasses left on-site would remain in an unsightly state for longer durations without 

2 assistance in their removal, and the duration would increase for larger sized animals. The 

3 unappealing sight and smell could reduce tourism activity at that particular beach, as visitors may 

4 choose to spend their money at other beaches or alternative recreation sites located further inland. 

5 However, tourists may want to see a live stranded animal or a carcass, which could create a beneficial 

6 impact on surrounding business. 

7 4.6.1.2 Alternative A2- Status Quo 

8 Under Alternative A2, the current SAs would be renewed and current stranding response activities 

9 would continue without the issuance of Final SA criteria. Minor to moderate, long-term adverse 

10 effects to stranding network members would be expected to occur under Alternative A2. Current SA 

11 holders would continue their response activities and would continue to incur operating costs 

12 associated with these activities. However, SA holders whose response activities attract external 

13 funding may see minor to moderate, indirect beneficial impacts. 

14 Negligible adverse effects to tourism businesses, such as accommodations and restaurants, could be 

15 expected from Alternative A2. Some carcasses may still be left on-site to decompose naturally. The 

16 unappealing sight and smell could reduce tourism activity at that particular beach, as visitors may 

17 choose to spend their money at other beaches or alternative recreation sites located further inland. 

18 However, tourists may want to see a live stranded animal, a carcass, or the response activities, which 

19 could create a beneficial impact on surrounding business. 

20 4.6.1.3 Alternative A3 

21 Under Alternative A3, SAs would be issued to any applicants after review, the new SA template 

22 would not be utilized, and the Final SA criteria would not be issued. Minor to moderate adverse 

23 effects on current stranding network members would likely occur under Alternative A3. Operating 

24 expenses for current network members may be offset by the addition of new SA holders. As the 

25 number of SA holders increases, travel time and expense should reduce, as there would likely be 

26 greater coverage for a particular geographic area. Given that the funding sources for network 

27 activities are likely finite, increased competition for funds may result in reduced opportunities for 

28 current network members. However, fundraising experience, established relationships with donors, 

29 and familiarity with competitive funding opportunities (i.e., Prescott Grant Program), should provide 

30 current network members with continued access to funds. 
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1 New SA holders would likely bear minor to moderate adverse economic impacts due to the operating 

2 costs related to their new response activities and limited fundraising experience and opportunities. 

3 The extent of the impact on these new network members would depend on the nature of their pre4 existing capacity, their authorized functions (dead animal response, live animal response, and/or 

5 rehabilitation), and their fundraising history. New SA holders cooperating within large organizations, 

6 for example, may have sufficient facilities and financial resources to ensure economic independence 

7 or fundraising success. 

8 Negligible beneficial effects on tourism businesses would likely occur under Alternative A3. 

9 Maintaining the current stranding network and adding new participants would enhance 

10 responsiveness to nearby live and dead marine mammals. 

11 4.6.1.4 Alternative A4- Preferred Alternative 

12 Under Alternative A4, the Final SA criteria and the new SA template would be implemented and 

13 current and future stranding response activities would occur. Alternative A4 is similar to Alternative 

14 A3, but under Alternative A4 the Final SA criteria would be implemented. Moderate to major, 

15 adverse effects to the current SA holders would be expected to occur. As the Final SA criteria are 

16 more stringent than what is currently in place, existing SA holders may need more training or may 

17 need to alter existing practices in order to meet the new criteria. However, the level of impacts 

18 would depend on the current practices of SA holders. For SA holders who would require no or few 

19 changes to meet the new criteria, impacts would be small. Similarly, larger facilities who engage in a 

20 wide variety of activities, in addition to stranding response and rehabilitation activities would bear a 

21 relatively lower burden in terms of costs. New SA holders, and current SA holders that have 

22 difficulty implementing the new SA criteria, would bear moderate to major, adverse impacts 

23 depending on their ability to take on new response and rehabilitation activities. With the addition of 

24 new SA holders, existing stranding network members may face competition for donations and other, 

25 presumably finite, sources of funds available for marine mammal stranding and rehabilitation 

26 activities. 

27 Negligible beneficial effects on tourism businesses would likely occur under Alternative A4, similar 

28 to those described under Alternative A3. 
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1 4.6.1.5 Alternative A5 

2 Under Alternative A5, the Final SA criteria and the new SA template would be implemented and 

3 response to threatened, endangered, or rare animals would be required. Minor to major, long-term 

4 adverse effects to SA holders would be likely to occur. These impacts are similar to those described 

5 in Alternatives A3 and A4, but they would also depend on the proportion of stranded marine 

6 mammals that are not rare, threatened, or endangered and whether or not the network member 

7 chooses to continue responding to those animals. While implementation of the Final SA criteria may 

8 increase operating costs, the impact may be offset if there was a reduction in responses to stranding 

9 events under Alternative A5. The reduction in responses could occur if new SA holders covered 

10 geographic areas previously covered by another network member. 

11 Negligible beneficial effects on tourism businesses would likely occur under Alternative A5, similar 

12 to those described under Alternative A3. 

13 4.6.2 Carcass Disposal Alternatives 

14 4.6.2.1 Alternative B1- No Action 

15 Under Alternative B1, no carcass disposal would occur and carcasses would remain on the beach to 

16 naturally decompose. Carcasses would be left wherever they naturally occurred. Removal of non17 ESA listed carcasses could be conducted by Federal (not including NMFS), state, and local agencies 

18 authorized under MMPA 109(h), but this would likely be localized and limited. Minor to moderate 

19 beneficial effects are likely to occur for existing stranding network members that participate in other 

20 activities besides response and carcass disposal. The elimination of carcass disposal activities would 

21 lower operating costs for these members. 

22 Carcasses left on-site to decompose would remain in an unsightly state for a longer period of time 

23 without assistance in their removal. The duration would increase for larger sized animals. Some 

24 strandings sites may be in areas of human activity, including commercial areas such as beachfront 

25 hotels, casinos, businesses, or natural areas (national parks, seashore, or NERRs). This could result in 

26 negligible, adverse impacts in terms of lost revenues, restaurants, and parks in the immediate vicinity 

27 of the carcass(es), if the public chose to avoid the area. The resulting unappealing sight and odors 

28 could reduce tourism activity at that particular beach, as visitors may choose to spend their money at 

29 other beaches or alternative recreation sites further inland. However, negligible, short-term beneficial 

30 effects on surrounding businesses may occur if people visit the area to view the carcass. 
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1 4.6.2.2 Alternative B2- Status Quo 

2 Under Alternative B2, current methods of carcass disposal would continue. Negligible adverse effects 

3 on tourism activities could occur from Alternative B2. Under current response activities, some 

4 carcasses may be left on beaches. Carcasses may be left in areas of recreational and tourism 

5 activities, such as beachfront hotels or natural areas. However, carcasses would not be left on 

6 actively used beaches. Carcasses could be left on remote beaches that may be part of a national park, 

7 seashore, or NERR. The foul odors and the sight of a decomposing animal may result in visitors 

8 avoiding the area. This impact would be negligible, as visitors could still participate in activities 

9 within the area not located near the carcass. However, negligible, short-term beneficial effects on 

10 surrounding businesses may occur if people visit the area to view the carcass. 

11 Stranding network participants currently authorized for dead marine mammal response would likely 

12 bear minor to moderate adverse effects due to continued time and expense associated with carcass 

13 disposal activities. 

14 4.6.2.3 Alternative B3- Preferred Alternative 

15 Under Alternative B3, current methods of carcass disposal would continue with a recommendation to 

16 transport chemically euthanized animal carcasses off-site. Alternative B3 is similar to Alternative B2, 

17 except that Alternative B3 recommends (but would not require) the removal of chemically euthanized 

18 carcasses to an off-site location. The economic impacts from Alternative B3 would be the same as 

19 those described under Alternative B2, with one exception. Chemically euthanized carcasses would be 

20 removed and towed off-site to a hazardous waste landfill. Towing animals off-site would be 

21 expensive and the cost would be incurred by the stranding network member. The adverse effect on 

22 individual members would be negligible, minor, or major, depending on the number of animals 

23 chemically euthanized. The costs of transporting the chemically euthanized carcass off-site could 

24 vary depending on the size of the animal, transport distance, or the means of transport. Some 

25 stranding network members may bear a greater cost burden if stranding events tend to involve large 

26 animals, multiple carcasses, or if the carcass needs to be transported a great distance for disposal. 

27 Adverse effects could also occur due to increased costs affiliated with rendering or incinerating 

28 activities or fees imposed by the disposal site, including the need to obtain local or state permits for 

29 beach or at sea disposal. 

30 Negligible negative impacts on local tourism businesses could occur under Alternative B3. 

31 Transporting chemically euthanized carcasses off-site would reduce the instances when an unsightly 
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1 carcass would deter visitors from a particular location. However, other carcasses may be left at 

2 stranding sites. 

3 4.6.3 Rehabilitation Activities Alternatives 

4 4.6.3.1 Alternative C1- No Action 

5 Under Alternative C1, current SAs would expire, stranding response would end, and animals would 

6 not be taken into rehabilitation. Major, long-term, adverse effects on facilities that focus primarily on 

7 rehabilitation activities could occur under Alternative C1. Many facilities in this category may cease 

8 operation, unless their activities could be shifted (e.g., they are able to redirect rehabilitation efforts to 

9 animals other than marine mammals). Larger facilities that also engage in other activities may 

10 experience a minor, long-term positive effect in terms of the reduced operating costs from the 

11 elimination of rehabilitation activities. 

12 4.6.3.2 Alternative C2- Status Quo 

13 Under Alternative C2, current rehabilitation activities would continue, but the final Rehabilitation 

14 Facility Standards would not be implemented. Minor to moderate, adverse effects on rehabilitation 

15 facilities would be expected, as continued expenses would be incurred from rehabilitation activities. 

16 Rehabilitation facilities would operate as they currently do and therefore continue to incur supply, 

17 equipment, personnel, and maintenance expenses. 

18 4.6.3.3 Alternative C3- Preferred Alternative 

19 Under Alternative C3, new SAs would be issued, rehabilitation activities would continue, and the 

20 final Rehabilitation Facility Standards would be implemented. Alternative C3 would be the same as 

21 Alternative C2, with two exceptions. Alternative C3 would issue new SAs and implement the 

22 Rehabilitation Facility Standards. Minor to major, adverse effects on rehabilitation facilities would 

23 be expected to occur from this alternative. The Rehabilitation Facility Standards would be 

24 implemented and facilities would need to upgrade to comply with the minimum standards, in order to 

25 maintain or obtain their SAs. The level of impact would depend on each facility, if they need to 

26 upgrade, and how much they would need to upgrade to meet the minimum standards. Current 

27 rehabilitation facilities were contacted to determine the estimated costs of upgrading each facility. 

28 The East Coast facility that responded to NMFS’ request for information estimated that it would cost 

29 $75,000 to upgrade its pinniped rehabilitation facilities. Of the West Coast facilities that responded, 

30 the total estimated costs to upgrade facilities ranged from $0 (a facility where the standards were 
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1 already met) and $48,000 (cetacean and pinniped facility) on the low end to $1.9 million and $7 

2 million (both pinniped facilities) on the high end. Excluding the facility that reported $7 million in 

3 impacts, the average impact among the facilities that responded is estimated to be $518,334. 

4 4.6.3.4 Alternative C4 

5 Under Alternative C4, new SAs would be issued, rehabilitation activities would continue, and the 

6 final Rehabilitation Facility Standards would be implemented. Alternative C4 would be the same as 

7 Alternative C3, with the exception that the rehabilitation of non-ESA and non-rare marine mammals 

8 would be optional. Alternative C4 would adversely affect rehabilitation facilities in the same manner 

9 as Alternative C3. Alternative C4 could adversely affect facilities to a lesser extent, however, since 

10 under the rehabilitation of non-rare and non-ESA species would only be optional. 

11 4.6.4 Release of Rehabilitated Animals Alternatives 

12 4.6.4.1 Alternative D1- No Action 

13 Under Alternative D1, current SAs would expire, stranding response and rehabilitation would cease, 

14 and there would be no animals to release. Eelease activities would cease as stranding response and 

15 rehabilitation activities ended. Eliminating activities related to the release of rehabilitated marine 

16 mammals would eliminate the expenses related to these activities. 

17 4.6.4.2 Alternative D2- Status Quo 

18 Under Alternative D2, current release activities would continue, adaptive changes to release activities 

19 would not be permitted, and the final Release criteria would not be implemented. Minor to moderate, 

20 adverse effects on rehabilitation facilities would be expected, as continued expenses would be 

21 incurred from release activities. Facilities that release more animals, larger species of marine 

22 mammals, or those that need to travel greater distance to release animals would incur a greater share 

23 of expenses. 

24 4.6.4.3 Alternative D3- Preferred Alternative 

25 Under Alternative D3, new SAs would be issued, release activities would continue, adaptive changes 

26 to release activities would be permitted, and the final Release criteria would be implemented. 

27 Alternative D3 would be the same as Alternative D2, except that new SA holders could be added and 

28 the release criteria would be implemented. Minor to moderate, adverse effects may be borne by 

29 rehabilitation facilities. Costs may increase at each facility in order to comply with the release 
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1 criteria. However, the possible addition of rehabilitation facilities could help offset the release 

2 activities and costs for some facilities. 

3 4.6.5 Disentanglement Alternatives 

4 4.6.5.1 Alternative E1- No Action 

5 Under Alternative E1, there would be no disentanglement network. Minor to moderate, beneficial 

6 effects on current participants could occur from the elimination of expenses incurred from 

7 disentanglement activities. 

8 4.6.5.2 Alternative E2- Status Quo 

9 Under Alternative E2, the disentanglement network would continue the current activities with no 

10 modifications or new members added. Minor to moderate, adverse effects would continue to be borne 

11 by participants engaged in disentanglement activities. 

12 4.6.5.3 Alternative E3- Preferred Alternative 

13 Under Alternative E3, the disentanglement network would continue the current activities on the East 

14 Coast with modifications to the West Coast network. In addition, the Disentanglement Guidelines and 

15 training prerequisites would be implemented nationwide. East Coast participants already follow these 

16 guidelines and training prerequisites, and therefore no additional impacts would be expected. Minor 

17 to moderate, adverse effects would be borne by West Coast participants due to modifications of 

18 current operations and training expenses. 

19 4.6.6 Biomonitoring and Research Activities Alternatives 

20 4.6.6.1 Alternative F1- No Action 

21 Under Alternative F1, biomonitoring and research activities would not occur. No effects on 

22 socioeconomics would be expected to occur under Alternative F1. 

23 4.6.6.2 Alternative F2 Status Quo 

24 Under Alternative F2, the new ESA/MMPA permit would continue the current biomonitoring and 

25 research activities. Minor to moderate, adverse effects could occur under Alternative F2 depending on 

26 the nature of current biomonitoring and research activities and the ongoing personnel and research 

27 expenses. 
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Final Programmatic Environmental Impact Statement February 2009 

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1 4.6.6.3 Alternative F3- Preferred Alternative 

2 Under Alternative F3, the new ESA/MMPA permit would be issued to include current and future 

3 biomonitoring and research activities. Minor to moderate, adverse effects could occur under 

4 Alternative F3 depending on the nature of new biomonitoring and research activities and the ongoing 

5 personnel and research expenses. 
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Final Programmatic Environmental Impact Statement 

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1 Table 4-2. Summary Matrix of Impacts 

Impact Area 

Alternatives Biological Resources Water & Sediment Quality Cultural Resources Stranding Agreements & Response Alternative A1- No Action No Action- SA's expire, stranding response would end.

Moderate, adverse effects on marine mammals, as stranded animals would be removed from the population. Valuable information on marine mammal health would not be collected. No effects on protected and sensitive habitats, SAV and macroalgae, sea turtles, fish, shellfish, other invertebrates, and birds. 

No effects on water and sediment quality. No effects on cultural resources. 

Alternative A2- Status Quo Status Quo- Current SAs would be renewed, current stranding response activities continue. Final SA criteria would not be issued. 

Minor, short-term adverse effects on protected and sensitive habitats, SAV and macroalgae, sea turtles, shellfish, and birds from equipment use or leaks on beaches/nearshore waters and the presence of responders. Minor to moderate, adverse effects on marine mammals would be expected from response activities and if new SAs are not issued. 

Minor, short-term adverse effects on surrounding sand and nearshore waters could occur from equipment leaks and euthanasia solution or other environmental contaminants in tissue, blood, and other body fluids. 

Potential minor, adverse effects on submerged cultural resources or resources buried in sand from equipment and vehicle use on beaches and nearshore waters. There would not be any effects on Alaska Natives, Native American tribes, or other aboriginal people’s cultural uses of coastal resources. 

Alternative A3 SAs issued to any applicants after review, new SA template would not be utilized. Final SA criteria would not be issued. Current and future activities included.

Same effects on biological resources as Alternative A2. Some beneficial impacts could come from allowing new SA holders to be added, given that they have the proper experience with marine mammal response, as geographic coverage would increase and new rehabilitation facilities may be added. 

Same effects as Alternative A2. Same effects as Alternative A2. 

Alternative A4 (Preferred) Final SA criteria would be implemented, new SA template would be utilized, current and future activities included. 

Same effects on biological resources as Alternative A2. Beneficial impacts from use of new techniques and tools during response activities and ability to add new SA holders. Long-term beneficial effects on marine mammals would be expected to occur with the implementation of SA criteria. 

Same effects as Alternative A2. Same effects as Alternative A2. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement 

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Table 4-2. Summary Matrix of Impacts (con

Impact Area 

Alternatives Biological Resources Water & Sediment Quality Cultural Resources Stranding Agreements & Response Alternative A5 Final SA criteria would be implemented, new SA template would be utilized, and response to threatened endangered or rare animals would be required.

Same effects from stranding response activities as Alternative A2, with two exceptions. Beneficial effect on threatened, endangered, or rare animals and an adverse effect on other species. Same effects from the implementation of SA criteria as Alternative A4. 

Same effects as Alternative A2. Same effects as Alternative A2. 

Carcass Disposal Alternative B1- No Action No Action- SA's expire, no carcass disposal would occur, carcasses would be left where stranded.

 Potential adverse effects could occur from leaving carcasses on the beach to naturally decompose. Animal carcasses may contain contaminants, which could negatively impact the surrounding environment. No effects on protected and sensitive habitats, SAV and macroalgae, sea turtles, fish, shellfish, other invertebrates, and birds. 

 Potential adverse effects could occur from leaving carcasses on the beach to naturally decompose. Animal carcasses may contain contaminants, which could negatively impact the surrounding water and sediment quality. 

No effects on cultural resources. 

Alternative B2- Status Quo Status Quo- Current methods of carcass disposal continue.

Minor to moderate, short- and long-term adverse effects, as animal carcasses may contain persistent environmental contaminants or euthanasia solution, which could negatively impact the surrounding environment. Other adverse effects from burial, equipment use, spills of hazardous materials or wastes from equipment or vessels. Disposal at sea might allow contaminants to re-enter the marine environment, but would provide a benefit by serving as a food sources for marine organisms. 

Minor, short-term adverse effects on water and sediment quality could occur from equipment leaks; euthanasia solution or other contaminants in tissue, blood, and other body fluids; spills of hazardous materials or wastes from vessels. Burial and equipment use may have a negligible impact 

on erosion. 

Potential minor, long-term, adverse effects on submerged cultural resources or resources buried in sand from beach burial, and equipment and vehicle use on beaches and nearshore waters. There would not be any effects on Alaska Natives, Native American tribes, or other aboriginal people’s cultural uses of coastal resources. 

Alternative B3 (Preferred) Status Quo with the recommendation to transport chemically euthanized animal carcasses off-site.

Same effects as Alternative B2, with one exception. Chemically euthanized carcasses would not be buried on-site, minimizing some of the adverse effects. 

Same effects as Alternative B2. Same effects as Alternative B2. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement 

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Table 4-2. Summary Matrix of Impacts (con

Impact Area 

Alternatives Biological Resources Water & Sediment Quality Cultural Resources Rehabilitation Activities Alternative C1- No Action No Action- Current SAs would expire, stranding response would cease, and animals would not be rehabilitated.

Moderate, long-term, adverse effects as marine mammals would not be taken into rehabilitation and most would likely die from injuries or disease. No effects on protected and sensitive habitats, SAV and macroalgae, sea turtles, fish, shellfish, other invertebrates, and birds. 

No effects on water and sediment quality. No effects on cultural resources. 

Alternative C2- Status Quo Status Quo- Current rehabilitation activities would continue. Final Rehabilitation Facility Standards would not be implemented.

Minor to major, short- and long-term, beneficial and adverse effects on marine mammals. Potential adverse effects from sampling, anesthesia, disease, euthanasia, and not implementing the Rehabilitation Facility Standards No effects on protected and sensitive habitats, SAV and macroalgae, sea turtles, fish, shellfish, other invertebrates, and birds. 

Minor adverse effects due to use of open ocean/bay net pens and temporary pools and contamination from wastes, pathogens, etc. Rehabilitation facilities would have necessary permits for wastewater discharges. 

Potential minor to major adverse effects on from the use of temporary pools and net pens, depending on where they are sited. Net pens may disturb or damage submerged cultural resources. 

Alternative C3 (Preferred) New SAs would be issued, rehabilitation activities continue. Final Rehabilitation Facility Standards would be implemented.

Same effects as Alternative C2, with one exception. Rehabilitation Facility Standards would decrease the risk of disease transmission ensure a healthy environment, maximize the success of rehabilitation, and increase the potential for release to the wild. Would reduce animal pain and suffering. 

Same effects as Alternative C2. Same effects as Alternative C2. 

Alternative C4 New SAs would be issued, rehabilitation activities would continue. Rehabilitation of threatened endangered and rare animals would be required; response to other animals would be optional. Final Rehabilitation Facility Standards would be implemented.

 Same effects as Alternative C3, with a few exceptions. Adverse effects on animals that are not rare, threatened, or endangered. These animals often serve as models for other species and this would be an indirect adverse affect on rare, threatened, and endangered species. 

Same effects as Alternative C2. Same effects as Alternative C2. 

Release of Rehabilitated Animals Alternative D1- No Action No Action- Current SAs would expire, stranding response and rehabilitation would cease, and therefore there would be no animals to release.

Adverse effects as marine mammals would not be released back to the wild, which negatively impacts all species, but especially threatened or endangered species. Beneficial effect on wild populations, as there would not be the risk of introducing a diseased animal that could potentially infect other marine mammals. No effects on protected and sensitive habitats, SAV and macroalgae, sea turtles, fish, shellfish, other invertebrates, and birds. 

No effects on water and sediment quality. No effects on cultural resources. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement 

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Table 4-2. Summary Matrix of Impacts (con

Impact Area 

Alternatives Biological Resources Water & Sediment Quality Cultural Resources Release of Rehabilitated Animals Alternative D2- Status Quo Status Quo- Current release activities would continue. Adaptive changes to release activities would not be permitted. Final release criteria would not be implemented.

Minor, short- and long-term, adverse and beneficial effects on marine mammals. 

Release activities (tagging, marking, and transport) may have adverse effects. Released animal could carry a zoonotic disease and infect wild population. Adverse effects on all biological resources from equipment use, spills of hazardous materials or wastes from equipment or vessels. 

Minor, short-term, direct adverse effects could occur from spills of hazardous materials or wastes from release vessels or leaks from equipment into sand or surrounding waters. 

Minor, long-term, adverse effects on cultural resources buried in sand from equipment and vehicle use on beaches. 

Alternative D3 (Preferred) New SAs would be issued, release activities continue. Final release criteria would be implemented and would include adaptive management of release activities.

Same effects as Alternative D2, with one exception. Release criteria would be implemented and may reduce the effects on marine mammals. 

Same effects as Alternative D2. Same effects as Alternative D2. 

Disentanglement Activities Alternative E1- No Action No Action- No disentanglement network. 

Major, long-term adverse effects on marine mammals from ending the Disentanglement Network as animals would have increased pain and suffering and would most likely die. No significant effects on protected and sensitive habitats, SAV and macroalgae, sea turtles, fish, shellfish, other invertebrates, and birds. Gear on an entangled animal may be shed and become marine debris, which could potentially harm biological resources. 

No effects on water and sediment quality. No effects on cultural resources. 

Alternative E2- Status Quo Status Quo- Disentanglement network would continue current activities, no modifications or new members added

Minor, short-term adverse effects on protected and sensitive habitats, SAV and macroalgae, sea turtles, fish, shellfish, other invertebrates, birds, and marine mammals from spills of hazardous materials or wastes from vessels. Minor to major, short- and long-term, beneficial and adverse effects on marine mammals. Disentanglement would continue; new responders could not be added. Animal adverse reactions to close approaches, physical/chemical restraint, or be injured during the process. 

Minor, short-term, adverse effects could occur from spills of hazardous materials or wastes from release vessels. 

No effects on cultural resources. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement 

4-75 

Table 4-2. Summary Matrix of Impacts (con

Impact Area 

Alternatives Biological Resources Water & Sediment Quality Cultural Resources Disentanglement Activities Alternative E3 (Preferred) Disentanglement network would continue current activities on East Coast with modifications to West Coast network. The Disentanglement Guidelines and training prerequisites would be implemented.

Same effects as Alternative E2, except that new responders and techniques could be added and Disentanglement Guidelines/training would be in place to reduce adverse effects. 

Same effects as Alternative E2. No effects on cultural resources. 

Biomonitoring & Research Activities Alternative F1- No Action No Action- Biomonitoring and research activities would not occur.

Adverse effects on marine mammals as important health information would no longer be collected. No effects on protected and sensitive habitats, SAV and macroalgae, sea turtles, fish, shellfish, other invertebrates, and birds. 

No effects on water and sediment quality. No effects on cultural resources. 

Alternative F2- Status Quo Status Quo- New ESA/MMPA permit would continue current biomonitoring and research activities.

Minor, short-term adverse effects on protected and sensitive habitats, SAV and macroalgae, sea turtles, fish, shellfish, other invertebrates, birds, and marine mammals from spills of hazardous materials or wastes from vessels or leaks from equipment into sand or surrounding waters. Protected and sensitive habitats and SAV and macroalgae could be damaged by vessels/researchers. Sea turtles/birds and their nests could be disturbed/ damaged. Fish may be caught in nets or disturbed. Minor to major, short- and long-term, adverse effects on marine mammals from close approach, tagging, marking, restraint, handling, capture, transport, sampling, and other activities. Long-term beneficial effects from collection of health information. 

 Minor, short-term, direct adverse effects could occur from spills of hazardous materials or wastes from release vessels or leaks from equipment into sand or surrounding waters. 

Adverse effects would not likely occur. Potential effects on submerged cultural resources or resources buried in sand from equipment and vehicle use on beaches and vessel use in nearshore waters. 

Alternative F3 (Preferred) New ESA/MMPA permit would be issued to include current and future biomonitoring and research activities.

Same effects as Alternative F2, with other adverse effects from new research activities. The increase in research activities would have a beneficial affect on marine mammals, as more health information would be collected. 

Same effects as Alternative F2. Same effects as Alternative F2. 

1 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

5-1 

1 5. Mitigation 

2 5.1 Introduction 

3 The purpose of mitigation is to avoid, minimize, or eliminate negative impacts on the affected 

4 resources from a proposed action. Mitigation measures have been developed for alternatives where a 

5 significant impact would likely occur. Measures are described under each resource area and 

6 alternative, as necessary. 

7 5.2 Biological Resources 

8 5.2.1 Stranding Agreements and Response Alternatives 

9 Under Alternatives A2, A3, A4, and A5, measures would be taken to avoid protected and sensitive 

10 habitats, where feasible. However, many strandings occur in protected areas, including: national 

11 parks, monuments, seashores, and forests; NMSs; NERRs; wilderness areas; fishery management 

12 areas; and state and local parks. When response activities must occur in these areas, the proper 

13 authorities would be contacted to coordinate the response activities, to determine the manner in which 

14 a response may occur (if it is permitted at all), and to minimize impacts of a response. In situations 

15 where EFH may be impacted by response activities, the appropriate NMFS EFH Coordinator would 

16 be contacted. Nesting sea turtles and birds would be avoided during responses, and response 

17 activities would be coordinated with the USFWS and/or appropriate state agency/agencies to ensure 

18 there would be no adverse impacts. Article II, Part C, Number 2 of the SA template requires stranding 

19 network participants to coordinate with Federal, state, and local officials and employees in matters 

20 supporting the purposes of their SA (see Appendix C). The SA template (Article III and Article IV, 

21 Part B, Number 4) would require SA holders to make every reasonable effort to assist in the clean-up 

22 of beach areas where activities such as necropsy or specimen collection were conducted, by removing 

23 trash and other debris, and disposing of or assisting in the disposal of offal and other waste parts from 

24 the carcass. NMFS would develop spill prevention best management practices for responders to use 

25 to reduce the incidence of spills from equipment, euthanasia solution, etc. These measures would 

26 help protect the surrounding biological resources, particularly when the response was conducted in a 

27 sensitive area. 

28 Capture and restraint procedures would be performed or directly supervised by qualified personnel 

29 and if possible, an experienced marine mammal veterinarian would be present to carry out or provide 

30 direct on-site supervision of all activities involving the use of anesthesia and sedatives. Only 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

5-2 

1 personnel experienced in capture and sampling techniques would be used to complete the activities as 

2 quickly as possible. For pinnipeds, responders would carry out activities efficiently, such that the 

3 total time they are occupying beach haul-out areas, and total number of times a site is disturbed, are 

4 minimized. Response to stranded pinnipeds in a rookery situation would not be authorized under a 

5 SA, but would only be performed under the authority of the MMHSRP ESA/MMPA permit in 

6 coordination with the Permit Holder/PI. Experienced personnel would be used during capture and 

7 restraint to complete the activities as quickly as possible. 

8 To prevent interactions with Florida manatees or sea turtles during on-water capture activities, vessel 

9 personnel would be informed that it is illegal to intentionally or unintentionally harm, harass, or 

10 otherwise “take” manatees or sea turtles. Netting activities would ease if a manatee or sea turtle is 

11 sighted in the vicinity of the vessel. If a manatee or sea turtle is accidentally captured, the vessel 

12 would immediately be stopped and either turned off or put in neutral. Tension on the net would be 

13 released to allow the animal the opportunity to free itself. Caution would be exercised when 

14 attempting to assist the animal in freeing itself. The appropriate USFWS Field Office and NMFS 

15 PR1 would be contacted immediately to report any incidents. 

16 Tagging animals for immediate release would be performed or directly supervised by qualified 

17 personnel. Pinniped flipper tags would be placed appropriately, so animals would not walk on or be 

18 irritated by them. The tag and/or instrument size and weight would be kept to the minimum needed to 

19 collect the desired data to minimize the potential for increased energetic costs of or behavioral 

20 responses to larger tags. Tag placement would be selected so that it will not interfere significantly 

21 with an animal’s ability to forage or conduct other vital functions. 

22 Potential adverse impacts from euthanasia would be minimized by the measures described below. 

23 Under Article IV, Part A, Number 1 of the SA template (Appendix C), euthanasia of animals would 

24 only be performed by the attending veterinarian or by a person acting on behalf of the attending 

25 veterinarian (i.e., under direct coordination or supervision). Euthanasia procedures would follow 

26 approved guidelines, such as those listed in the 2000 Report of the AVMA on Euthanasia (AVMA 

27 2001) or the CRC Handbook of Marine Mammal Medicine (Greer et. al 2001). Persons using 

28 controlled drugs would comply with all applicable Federal and state laws and regulations. This would 

29 include DEA regulations and any applicable state veterinary practice laws and regulations. Stranding 

30 network members would be authorized to euthanize ESA-listed species under the MMHSRP 

31 ESA/MMPA permit. In addition to the previous measures, euthanasia of ESA-listed species would 

32 require authorization and coordination with the appropriate NMFS regional stranding coordinator. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

5-3 

1 Potential impacts from the transport of animals to rehabilitation facilities could be minimized by 

2 following the APHIS “Specifications for the Humane Handling, Care, Treatment, and Transportation 

3 of Marine Mammals” (9 CFR Ch 1, Subpart E). If a commercial vehicle is used to transport an 

4 animal, these standards should be complied with. The “Live Animal Regulations” published by the 

5 International Air Transport Association (IATA) may also be used to minimize transport impacts 

6 (IATA 2006). Both sets of standards have specifications for containers, food and water requirements, 

7 methods of handling, and care during transit.

8 The Marine Mammal Oil Spill Response Guidelines (Appendix L) would be followed to prevent any 

9 potential impacts during response. The guidelines include information on data collection and chain10 of-custody procedures. Stranding responders would work with the Federal On-Scene Coordinator 

11 (FOSC) for oil spill response and consult with NMFS on appropriate response measures. 

12 Potential impacts from hazing would be minimized by using visual observations during the use of all 

13 acoustic deterrents. If a change in animal behavior is observed (other than moving away from the 

14 sound), the acoustic deterrent source would be shutdown. Procedures for the use of acoustic 

15 deterrents around ESA-listed species would be developed. Procedures for hazing killer whales are 

16 currently being drafted. Airguns would not be used around mysticetes to minimize any potential 

17 injuries. Seal bombs would not be used in the vicinity of an oil spill. Additional mitigation for 

18 hazing threatened and endangered species may be included as conditions of the ESA/MMPA permit. 

19 The MMHSRP would follow all mitigation measures for response to threatened and endangered 

20 species set forth by NMFS PR1 as conditions of their ESA/MMPA permit. 

21 5.2.2 Carcass Disposal Alternatives 

22 Under Alternatives B2 and B3, stranding network members would contact and coordinate with 

23 Federal, State, and/or local agencies prior to carcass disposal. Article II, Part C, Number 2 of the SA 

24 template requires stranding network participants to coordinate with Federal, state, and local officials 

25 and employees in matters supporting the purposes of their SA (see Appendix C). Beach burial and 

26 disposal in State waters would only occur after state and/or local authorities have given permission to 

27 conduct such activities. If necessary, stranding network members would obtain a permit to conduct 

28 these disposal activities. Burial in shoreline areas may be restricted for the protection of sensitive 

29 habitats, such as nesting shorebirds, vegetation, or dunes. Burial would not occur in wetland areas. 

30 Carcasses may be buried in upland areas where body fluids would not likely leach into groundwater. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

5-4 

1 Burial would also be deep enough so that carcasses would not be dug up by scavengers or uncovered 

2 by wave action. 

3 If carcasses are known or assumed (based upon test results or prior knowledge of the species) to have 

4 contaminant levels that meet or exceed the definition of hazardous waste under EPA, state, and/or 

5 local regulations, they would be taken to an EPA-designated hazardous waste landfill for proper 

6 disposal. 

7 Non-toxic carcasses may be disposed in Federal waters without a permit. At-sea disposal of carcasses 

8 that are known to be hazardous waste may require EPA approval and a permit. These carcasses 

9 would be disposed of in an EPA designated ocean dumping site. All EPA dumping sites are managed 

10 to avoid or minimize impacts to the marine environment. Materials used to sink carcasses would be 

11 chosen to avoid or minimize any impacts to the marine environment. 

12 During carcass disposal and removal activities, measures would be taken to avoid protected and 

13 sensitive habitats. When these areas cannot be avoided, the proper authorities would be contacted to 

14 coordinate the disposal activities and minimize impacts. In situations where EFH may be impacted 

15 by response activities, the appropriate NMFS EFH Coordinator would be contacted. Activities would 

16 also be coordinated with State and/or local agencies to avoid or minimize impacts to nesting sea 

17 turtles or birds. 

18 5.2.3 Rehabilitation Activities Alternatives 

19 If NMFS selects Alternative A3 or A4 for SAs and response, it would implement the Final SA criteria 

20 (Appendix C) as mitigation for Alternatives C3 and C4. Under the SA criteria (Part C, Number 3) the 

21 rehabilitation facility should have and maintain an attending veterinarian experienced in marine 

22 mammal care that would be willing to assume responsibility for diagnosis, treatment, and medical 

23 clearance for release or transport of marine mammals in rehabilitation. Also, the attending 

24 veterinarian should provide a schedule of veterinary care that includes a review of the husbandry 

25 records; visual and physical examinations of all marine mammals in rehabilitation; and a periodic 

26 visual inspection of the facilities, protocols, Standard Operating Procedures, and case records. All 

27 documentation of the attending veterinarian’s experience would be submitted to NMFS for review 

28 prior to issuing an SA. Under Part C, Number 4 of the SA criteria the rehabilitation facility should 

29 have sufficient physical and financial resources to maintain appropriate animal care. The stranding 

30 network participant would have to submit a facility operation manual to NMFS for review prior to the 

31 issuance of an SA. All operations would be consistent with NMFS and other applicable Federal and 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

5-5 

1 State policies, guidelines, directives, regulations, and laws. Facilities would be reviewed by NMFS 

2 for compliance with their SA every 3 years, and may be put on probation, suspended, or have their 

3 SA terminated for any violations or non-compliance. 

4 Veterinary medical care standards (Sections 1.7 [for cetaceans] and 2.7 [for pinnipeds] in the 

5 standards) would ensure that veterinarians and other personnel have the appropriate knowledge and 

6 experience to properly care for and treat marine mammals. Veterinarians must have: arrangements to 

7 obtain and store medications required for the animals housed at the rehabilitation facility; access to a 

8 list of expert veterinarians to contact for assistance; and a minimum skill level to treat species most 

9 commonly encountered at the facility. Veterinary care would comply with any applicable state 

10 veterinary practice laws and regulations for the state in which the facility is located. Examples of the 

11 recommended standards for veterinarians include: completion of a course offering basic medical 

12 training with marine mammals; one year of clinical experience working with the marine mammal(s) 

13 most frequently admitted to the facility; one year of clinical veterinary experience post graduation; 

14 and membership in the International Association for Aquatic Animal Medicine. 

15 Potential adverse impacts under Alternative C3 and C4 from disease transmission would be 

16 minimized by measures in the Rehabilitation Facility Standards. Under Section 1.4 (cetaceans) and 

17 Section 2.4 (pinnipeds), quarantine facilities would be available and quarantine protocols would be in 

18 place for all incoming animals. Minimum quarantine standards include, but are not limited to: having 

19 separate filtration and water flow systems; providing sufficient space or solid barriers between animal 

20 enclosures to prevent direct contact; and maintaining equipment and tools strictly dedicated to the 

21 quarantine area. An evaluation and written veterinarian approval would be required before placing 

22 animals together after the quarantine period has been met. Standards include measures to reduce the 

23 spread of disease from open ocean/bay pens. Standards also include measures to prevent disease 

24 transmission from domestic and wild terrestrial animals to marine mammals and vice versa. All 

25 quarantine standards are described in Section 1.4 (for cetaceans) and Section 2.4 (for pinnipeds) of 

26 the standards. 

27 Handling and restraint procedures would be performed or directly supervised by qualified personnel 

28 and if possible, an experienced marine mammal veterinarian would be present to carry out or provide 

29 direct on-site supervision of all activities involving the use of anesthesia and sedatives. Only 

30 personnel experienced in handling and sampling techniques would be used in order to complete the 

31 activities as quickly as possible. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

5-6 

1 Potential adverse impacts from euthanasia under Alternative C3 and C4 would be minimized by the 

2 measures described below. Under Article IV, Part A, Number 1 of the SA template (Appendix C) 

3 and Section 9.0 of the Rehabilitation Facility Standards, euthanasia of animals would only be 

4 performed by the attending veterinarian or by a person acting on behalf of the attending veterinarian 

5 (i.e., under direct authorization or supervision). Persons administering the euthanasia should be 

6 knowledgeable and trained to perform the procedure, and competent in the performance of the 

7 technique. Each facility would have a written euthanasia protocol signed and periodically reviewed 

8 by the attending veterinarian. Euthanasia procedures would follow approved guidelines, such as 

9 those listed in the 2000 Report of the AVMA on Euthanasia (AVMA 2001) or the CRC Handbook on 

10 Marine Mammal Medicine (Greer et. al 2001). Persons using controlled drugs would comply with all 

11 applicable Federal and state laws and regulations. This would include DEA regulations and any 

12 applicable state veterinary practice laws and regulations. In addition to the measures listed above, 

13 rehabilitation personnel would require further authorization to euthanize ESA-listed species under the 

14 MMHSRP ESA/MMPA permit. Euthanasia of ESA-listed species would require authorization and 

15 coordination with the appropriate NMFS regional stranding coordinator. 

16 The Marine Mammal Oil Spill Response Guidelines (Appendix L) would be followed to ensure that 

17 rehabilitation facilities that accept oiled animals are properly equipped to handle their care. The 

18 guidelines specify housing requirements and considerations, including ventilation, quarantine, water 

19 supply, and waste water. The guidelines include information on data collection and chain-of-custody 

20 procedures. Rehabilitation facilities would work with the FOSC for oil spill response and consult 

21 with NMFS on appropriate rehabilitation measures. 

22 5.2.4 Release of Rehabilitated Animals Alternatives 

23 If NMFS selects Alternative A3 or A4 for SAs and response, it would implement the Final SA criteria 

24 (Appendix C) as mitigation for Alternative D3. Under the SA criteria (Part C, Number 3) the 

25 rehabilitation facility should have and maintain an attending veterinarian, on staff or consulting, 

26 experienced in marine mammal care that would be willing to assume responsibility for diagnosis, 

27 treatment, and medical clearance for release. All documentation of the attending veterinarian’s 

28 experience would be submitted to NMFS for review prior to issuing an SA. Part C, Number 4 of the 

29 SA criteria requires the rehabilitation facility to have sufficient physical and financial resources to 

30 maintain appropriate animal care, including release activities. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

5-7 

1 Potential adverse impacts under Alternative D3 from disease transmission would be minimized by 

2 measures in the release criteria (Appendix C). Animals would be medically cleared by the attending 

3 veterinarian and their assessment team before a release determination is made. The medical 

4 assessment would include a hands-on physical examination. A review of the animal’s complete 

5 history, including all stranding information, diagnostic test results, and medical and husbandry 

6 records would also occur. NMFS would require some diagnostic testing to determine the risk to the 

7 health of wild marine mammal populations. Additional testing would be required if the animal was 

8 part of a UME. These procedures would minimize the potential for disease transmission from a 

9 released animal to the wild population. 

10 Additional measures to minimize the potential for disease transmission from rehabilitated ice seals 

11 (bearded, ringed, ribbon, and spotted seals) would be implemented in the NMFS Alaska Region. 

12 NMFS would not authorize responders to transport stranded ice seals beyond the geographic areas 

13 where they strand for the purposes of rehabilitation and release back to the wild. NMFS would 

14 review the following situations on a case-by-case basis: 1) an ice seal out-of-habitat; 2) ice seals as 

15 part of an official UME; and 3) stranded spotted seals in Bristol Bay, AK. NMFS would work with 

16 Alaska Native organizations (co-managers of these species) to determine the best possible solution for 

17 those ice seals. After consultation with these organizations, NMFS may re-evaluate this policy at any 

18 time, particularly with regard to changes in the status of ice seal populations and their habitat. 

19 Other potential impacts to released animals would be mitigated by the release criteria. In addition to 

20 a medical assessment, behavioral and developmental assessments would be conducted before a 

21 release determination. Developmental clearance would reasonably ensure that the animal has attained 

22 a sufficient age to be nutritionally independent, including the ability to forage and hunt. Behavioral 

23 clearance would include an assessment of an animal’s breathing, swimming, diving, locomotion on 

24 land (pinnipeds) foraging, and hunting abilities. An evaluation of an animal’s visual and auditory 

25 functions should be conducted if possible. Any behavioral conditioning must be eliminated prior to 

26 release such that the association of food rewards with humans is diminished. 

27 Handling and restraint procedures necessary for release would be performed or directly supervised by 

28 qualified personnel and if possible, an experienced marine mammal veterinarian would be present to 

29 carry out or provide direct on-site supervision of all activities involving the use of anesthesia and 

30 sedatives. Only personnel experienced in handling and sampling techniques would be used to 

31 complete the activities as quickly as possible. The veterinarian would also provide emergency 

32 procedures if necessary. For pinnipeds, personnel would carry out release activities efficiently, to 
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1 minimize the total time spent on the rookery/haul-out. Experienced personnel would be used during 

2 handling and restraint to complete the release activities as quickly as possible. Potential impacts from 

3 the transport of animals from rehabilitation facilities to release sites could be minimized by following 

4 the APHIS “Specifications for the Humane Handling, Care, Treatment, and Transportation of Marine 

5 Mammals” (9 CFR Ch 1, Subpart E). If a commercial vehicle is used to transport an animal, these 

6 standards should be complied with. The “Live Animal Regulations” published by the IATA may also 

7 be used to minimize transport impacts (IATA 2006). Both sets of standards have specifications for 

8 containers, food and water requirements, methods of handling, and care during transit.

9 The weight and dimensions of the instrument package relative to the animal’s size and mass, and 

10 duration of attachment, are important considerations in choosing a tag (Wilson and McMahon 2006). 

11 The tag size would be kept to the minimum needed to collect the desired data to minimize the 

12 potential for increased energetic costs of or behavioral responses to larger tags, but ensuring an 

13 adequate battery life to sustain the tag over the expected tag attachment duration (tags are expected to 

14 fall off after the failure of a corrodible link or the molt of a pinniped). Tag placement should be 

15 selected that will not interfere significantly with an animal’s ability to forage or conduct other vital 

16 functions. Pinniped flipper tags would be placed appropriately, so animals would not walk on or be 

17 irritated by them. A local anesthetic or analgesic would be administered prior to tagging or freeze 

18 branding an animal to minimize pain during application. 

19 5.2.5 Disentanglement Alternatives 

20 Under Alternative E3, impacts to all biological resources from a potential hazardous material spill 

21 would be mitigated by the implementation of training prerequisites and the Disentanglement 

22 Guidelines. The use of trained personnel and proper equipment and protocols would reduce the 

23 potential for spills. 

24 Disentanglements of ESA-listed cetaceans and pinnipeds would be authorized under the MMHSRP 

25 ESA/MMPA permit, with express consent of the Permit Holder/PI. The MMHSRP would follow all 

26 mitigation measures set forth by NMFS PR1 as conditions of their ESA/MMPA permit, and all 

27 activities will be conducted in consultation with and with the consent of the Permit Holder/PI. For 

28 large whale disentanglements, responders would approach animals gradually, with minimal noise to 

29 reduce any reaction. Responders would approach at slow speeds, avoid making sudden changes in 

30 speed or pitch, and avoid using reverse gear. Additional caution would be taken when approaching 

31 mothers and calves. Only responders with extensive experience operating vessels near large whales 
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1 would be involved in the vessel approaches. Responders would only include those individuals who 

2 have been sufficiently trained in large whale disentanglement according to the Disentanglement 

3 Guidelines (Appendix C). NMFS should develop more comprehensive guidelines for large whale 

4 disentanglement, as the current guidelines focus primarily on criteria for responder levels. Additional 

5 guidelines should include general protocols, policies, and procedures. NMFS should develop a 

6 database or other way to track qualifications of personnel. 

7 Small cetacean and pinniped disentanglement activities would be authorized under an SA. Only 

8 personnel experienced in small cetacean capture techniques would perform rescue activities. For 

9 disentanglements of pinnipeds on beach sites, responders would carry out activities efficiently, to 

10 minimize disturbance and the amount of time responders occupy the haul-out. 

11 For both small cetacean and pinniped disentanglements, NMFS should develop standard 

12 disentanglement protocols for these species and a training program similar to the Large Whale 

13 Disentanglement Network. In addition, NMFS may develop an additional Article or multiple Articles 

14 to be incorporated into the SA to authorize certain facilities (with personnel that have been trained 

15 and certified) to conduct capture/rescue and disentanglement activities. 

16 5.2.6 Biomonitoring and Research Alternatives 

17 The following mitigation measures are for actions proposed under Alternatives F2 and F3. 

18 5.2.6.1 Existing Mitigation Measures in NMFS PR1 Permits 

19 The MMHSRP would follow all mitigation measures set forth by NMFS PR1 as conditions of their 

20 ESA/MMPA permit. All NMFS PR1 marine mammal permits contain conditions intended to 

21 minimize the potential adverse effects of the research activities on the animals. These conditions are 

22 based on the type of research authorized, the species involved, information in the literature and from 

23 researchers themselves about the effects of particular research techniques and the responses of 

24 animals to these activities. Specifically, the following conditions would be stated as requirements in 

25 the MMHSRP’s ESA/MMPA permit: 

26 • General Approach Measures, Including Precautionary Measures for Young and Females 

27 with Young. Researchers would exercise caution when approaching animals and must retreat 

28 from animals if behaviors indicate the approach may be interfering with reproduction, 

29 feeding, or other vital functions. For females with young, researchers would immediately 

30 terminate efforts if there is any evidence that the activity may be interfering with pair-
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1 bonding or nursing and would not position the research vessel between the female and 

2 calf/pup. Researchers may not biopsy sample or tag cetacean calves less than six months of 

3 age or females attending calves less than six months of age. 

4 • Photography and Filming. The Permit Holder/PI and all researchers/CIs working under the 

5 proposed permit would obtain prior approval by NMFS PR1 for non-research related use of 

6 photographs, video, and/or film that were taken to achieve the research objectives, that such 

7 activities would not influence the conduct of research in any way, and any film approved for 

8 use would include a credit, acknowledgement, or caption indicating that the research was 

9 conducted under a permit issued by NMFS under the authority of the MMPA and/or ESA. 

10 • Research Personnel. The Permit Holder/PI would ultimately be responsible for all activities 

11 of any individual who is operating under the authority of the proposed permit. Addition of 

12 CIs would be approved by the Permit Holder/PI after reviewing their qualifications and 

13 research plans. All research personnel would be required to serve a research function and 

14 would be qualified to perform that function. 

15 • Reporting Conditions. An annual report would be submitted and reviewed by NMFS PR1 

16 for each year the permit is valid. For each marine mammal part taken, imported, exported, or 

17 affected, the annual report would include: a description of the part and its assigned 

18 identification number; source, collector, country of origin, and authorizing government 

19 agency (for imported samples) for each sample reported; a summary of the research analysis 

20 conducted on the samples; and a description of the disposition of any marine mammal parts. 

21 For live animal activities, the report would include a description of the species, numbers of 

22 animals, locations of activities, and types of activities for: live captures; stranding 

23 response/disentanglement of marine mammals and endangered/threatened species; specimen 

24 collections; euthanasia (including reason for euthanasia and the drugs used); and incidental 

25 harassment during activities. The report would include descriptions of the animals’ reactions, 

26 measures taken to minimize disturbance, research plans for the forthcoming year, and an 

27 indication as to when or if any results have been published or otherwise disseminated during 

28 the year. At the end of the proposed permit, a final report would be submitted that includes: 

29 a reiteration of the objectives, a summary of the research results and how they pertain to or 

30 further the research goals stated in the permit application and NMFS conservation plans; and 

31 an indication of where and when the research results would be published. 

32 • Research in Cooperation with Commercial Vessels. The permit specifically would not 

33 authorize the conduct of research activities aboard or in cooperation with commercial marine 
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1 mammal viewing vessels or aircraft while they are engaged in such commercial activity. 

2 Further, the permit would not authorize cooperation with any vessel or aircraft carrying any 

3 non-essential passengers (i.e. not essential for the conduct of the research) who either pay a 

4 fee in return for being allowed onboard the vessel or aircraft, or who, prior to or after the trip, 

5 give “donations” to the PI, CI(s) or Research Assistant(s). 

6 • Research Coordination. The Permit Holder/PI would be required to notify the appropriate 

7 NMFS Regional office at least two weeks in advance to coordinate the dates and locations of 

8 the authorized activities. The permit holder would also be required to coordinate with other 

9 researchers conducting the same or similar studies on the same species, in the same locations, 

10 and at the same time. 

11 • Import/Export of Marine Mammal Parts. No animal would be harassed or killed for the 

12 express purpose of providing specimens to be obtained and/or imported under the proposed 

13 permit actions. Parts imported under the authority of the proposed permit would be taken in a 

14 humane manner, and in compliance with the ESA, MMPA, Fur Seal Act, and any applicable 

15 foreign law. Importation of marine mammal parts is subject to the provisions of 50 CFR 

16 parts 14, 216, and 222. Any specimen(s) of species listed in the Appendices to CITES would 

17 be accompanied by valid CITES documentation from the exporting country, and, in the case 

18 of Appendix-I species, from the USFWS. 

19 • Biological Samples. All specimen materials collected or obtained under this authority would 

20 be maintained according to accepted curatorial standards. After completion of initial research 

21 goals, any remaining samples would be deposited into a bona fide scientific collection which 

22 meets the minimum standards of collection curation and data cataloging as established by the 

23 scientific community. 

24 • Additional Required Permits. The Permit Holder/PI would be required to obtain appropriate 

25 authorizations needed from other state or Federal agencies and would be reminded that the 

26 NMFS PR permit does not provide authorization for requirements under another state or 

27 Federal agencies’ jurisdiction. This would include obtaining necessary permits for research 

28 conducted in a NMS, national park, foreign country, etc. 

29 5.2.6.2 Mitigation Measures Common to Specific Research Activities 

30 A number of “good practice or protocol” measures are commonly followed by qualified, experienced 

31 personnel to minimize the potential risks associated with some of the research activities under the 

32 proposed permit actions. Consistent with the NMFS PR1 issuance criteria requiring personnel 
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1 authorized to take marine mammals under a permit to have qualifications commensurate with their 

2 duties, only qualified, experienced personnel would be allowed to perform intrusive procedures such 

3 as remote biopsy sampling and attachment of intrusive tags. Efforts would be made to avoid 

4 duplicate sampling of known animals through sharing of sighting and photo-identification 

5 information among permit holders. The following outlines common mitigation measures associated 

6 with specific research activities and/or species. 

7 Mitigation for Close Approach, Vessel and Aerial Surveys. To minimize disturbance and ensure 

8 adequate opportunities for photo-identification, tagging, and sampling, the researchers would 

9 approach animal(s) gradually from behind or alongside, rather than head on. An approach is defined 

10 as a continuous sequence of maneuvers involving a vessel, aircraft, or researcher’s body in the water, 

11 including drifting, directed toward an animal(s) for the purposes of conducting authorized research 

12 which involves one or more instances of coming closer than 100 yards (91.4 m) to a large whale(s) or 

13 50 yards (45.7 m) to a small cetacean (s), seal(s), or sea lion(s). Researchers would approach at slow 

14 speeds, avoid making sudden changes in speed or pitch, and avoid using reverse gear. The amount of 

15 time spent in close proximity to an animal(s) would be limited to the minimum necessary to meet 

16 research objectives. Whenever possible, four-stroke engines would be used, as they are quieter than 

17 two-stroke engines. Researchers would leave the vicinity of an animal(s) if the animal(s) shows a 

18 response to the presence of the research vessel or aircraft. Approaches to an individual animal would 

19 be limited and efforts to approach an individual would be discontinued of the animal displays 

20 avoidance behaviors, such as a change in its direction of travel or departures from normal breathing 

21 and/or dive patterns. Only personnel with extensive experience operating vessels and aircraft near 

22 animals would be involved in close approaches. 

23 If manatees are encountered during vessel surveys or other vessel activities, researchers would obey 

24 all speed zones and manatee no entry zones. If manatees are observed prior to an encounter, care 

25 would be taken to slowly maneuver away from the direction of the animals. If a manatee is 

26 encountered while on the water, a minimum distance of 50 ft (15.2 m) would be maintained at all 

27 times. If a manatee(s) approaches, vessel engines would be placed in neutral until the animal has 

28 passed. If manatees are located during aerial surveys, altitudes would be increased to 1,000 ft (300 

29 m), and surveys would ceases if the manatees appear to be affected by the over flight. The USFWS’ 

30 Jacksonville Office and NMFS PR1 would be contacted immediately to report any injuries that occur 

31 as a result of authorized research. 
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1 Mitigation for Capture, Restraint, and Handling. These procedures would be performed or directly 

2 supervised by qualified personnel and an experienced marine mammal veterinarian would be present 

3 to carry out or provide direct on-site supervision of all activities involving the use of anesthesia and 

4 sedatives. Only personnel experienced in capture and sampling techniques would be used in order to 

5 complete the activities as quickly as possible. The precautionary measures for young and females 

6 with young described above would be followed during cetacean capture/release activities. During 

7 capture/release activities, female animals determined to be in late-term pregnancy (late 2nd and 3rd 

8 trimester) will be tagged with a roto-tag so they can be avoided in subsequent sets, and then 

9 immediately released. 

10 Pinniped research activities would be carried out efficiently, to minimize the total time researchers are 

11 occupying the rookery/haul-out and the total number of times a site is disturbed. Stays on rookeries 

12 longer than five hours are justified only when it prevents additional disturbance of the site on 

13 subsequent days. To avoid respiratory distress, ischemia (restricted blood flow), or nerve damage, 

14 animals would be positioned properly (i.e., ventrally recumbent) during anesthesia (Dierauf 1990). 

15 Respiration and pCO2 (measure of carbon dioxide in the blood) would be monitored and oxygen 

16 administered, as needed to avoid prolonged breath holding during gas anesthesia, which can result in 

17 cardiac hypoxia (lack of oxygen to the heart muscle). Qualified personnel would be prepared to 

18 control or assist ventilations when using sedatives. An emergency kit would be readily available to 

19 respond to complications or emergencies. The animal’s body temperature would be closely 

20 monitored and steps would be taken to avoid hypo- and hyperthermia. Drug doses would be 

21 calculated on the researcher’s best estimate of an animal’s lean body mass and metabolic rate. 

22 To prevent interactions with Florida manatees or sea turtles during capture activities, vessel personnel 

23 would be informed that it is illegal to intentionally or unintentionally harm, harass, or otherwise 

24 “take” manatees or sea turtles. Netting activities would ease if a manatee or sea turtle is sighted in the 

25 vicinity of the vessel. If a manatee or sea turtle is accidentally captured, the vessel would 

26 immediately be stopped and either turned off or put in neutral. Tension on the net would be released 

27 to allow the animal the opportunity to free itself. Caution would be exercised when attempting to 

28 assist the animal in freeing itself. The appropriate USFWS Field Office and NMFS PR1 would be 

29 contacted immediately to report any incidents. 

30 Mitigation for Attachment of Tags and Scientific Instruments. Pinniped flipper tags would be 

31 placed appropriately, so animals would not walk on or be irritated by them. Care would be taken 

32 when attaching scientific instruments to pinnipeds to prevent thermal burns. The correct proportions 
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1 of epoxy hardener and resin catalyst would be used to prevent a “hot” mix and the minimum practical 

2 amount of epoxy would be used to prevent burning the animal. To minimize the risk of infections 

3 from implantable tags, appropriate instrument sterilization and sterile surgery techniques would be 

4 used. 

5 Measures to minimize the effects of attaching scientific instruments to cetaceans would include the 

6 use of stoppers to reduce the force of impact and limit the depth of penetration of the tips of 

7 subdermal tags. Arrow tips would be disinfected between and prior to each use, to minimize the risk 

8 of infection and cross-contamination. Suction cup mounted tags would be placed behind a cetacean’s 

9 blowhole so that there is no risk of any migration of the suction cup resulting in obstruction of the 

10 blowhole. A take would be considered to have occurred with any attempt made to tag an animal from 

11 a crossbow, air gun, or pole, even if that attempt is unsuccessful. No tagging takes would occur on 

12 large cetacean calves less than six months of age or females accompanying such calves. For small 

13 cetaceans, no tagging would occur for calves less than one year of age. 

14 The tag and/or instrument size and weight would be kept to the minimum needed to collect the 

15 desired data to minimize the potential for increased energetic costs of or behavioral responses to 

16 larger tags. Tag attachment methods would be minimally invasive, to minimize potential pain or 

17 infection. Tag placement would be selected so that it will not interfere significantly with an animal’s 

18 ability to forage or conduct other vital functions. All tagged animals should receive follow-up 

19 monitoring, including visual observations where feasible, to evaluate any potential effects from 

20 tagging activities. 

21 Mitigation for Marking. After freeze branding, the skin would be returned to normal temperature as 

22 quickly as possible using water. 

23 Mitigation for All Sampling Procedures. These procedures would be performed or directly 

24 supervised by qualified personnel and an experienced marine mammal veterinarian would be present 

25 to carry out or provide direct on-site supervision of all activities involving the use of anesthesia and 

26 sedatives. A marine mammal veterinarian or other qualified personnel would monitor the physiologic 

27 state of each animal (e.g., by monitoring respiratory rate and character, heart rate, body temperature, 

28 and behavioral response to handling and sampling procedures). Animals that are physically 

29 restrained but continue to struggle or show signs of stress would be released immediately to minimize 

30 the risk that continued stress would lead to capture myopathy. 
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1 Mitigation for Biopsy Sampling. During cetacean biopsy sampling, a take would be considered to 

2 have occurred with any attempt made to biopsy dart an animal from a crossbow, air gun, or pole, even 

3 if that attempt is unsuccessful. In addition, no biopsy sampling takes would occur on large cetacean 

4 calves less than six months of age or females accompanying such calves. For small cetaceans, no 

5 biopsy sampling would occur for calves less than one year of age. Sterile, disposable biopsy punches 

6 would be used to minimize the risk of infection and cross-contamination. Where disposable 

7 equipment is not available, liquid chemical sterilants would be used with adequate contact times (as 

8 indicated on the product label) to affect proper sterilization. Instruments would be rinsed with sterile 

9 water or saline before use on animals. Care would be taken to avoid contact of equipment 

10 disinfectants with an animal’s skin, and disinfectant agents would be changed periodically to avoid 

11 growth of resistant strains of microorganisms. 

12 Mitigation for Blood Sampling. The volume of blood taken from individual animals at one time 

13 would not exceed more than 0.5-1 percent of its body weight, depending on taxa (Dein et al. 2005). 

14 Qualified researchers should not need to exceed three attempts (needle insertions) per animal when 

15 collecting blood. If an animal cannot be adequately immobilized for blood sampling, efforts to 

16 collect blood would be discontinued to avoid the possibility of serious injury or mortality from stress. 

17 Sterile, disposable needles would be used to minimize the risk of infection and cross-contamination. 

18 Where disposable equipment is not available, liquid chemical sterilants would be used with adequate 

19 contact times (as indicated on the product label) to affect proper sterilization. Instruments would be 

20 rinsed with sterile water or saline before use on animals. Care would be taken to avoid contact of 

21 equipment disinfectants with an animal’s skin, and disinfectant agents would be changed periodically 

22 to avoid growth of resistant strains of microorganisms. 

23 Mitigation for Ultrasound Sampling. Rectal and vaginal transducer probes will be well lubricated 

24 during sampling. Care will be taken to avoid introducing foreign matter into the vaginal canal. 

25 Sedation may be used to minimize animal discomfort. Ultrasound procedures on cetaceans will take 

26 place in water as often as possible. 

27 Mitigation for Incidental Mortality. To ensure that the total number of observed mortalities does not 

28 exceed permitted levels, the Permit Holder/PI would notify NMFS PR1 of research-related mortalities 

29 by phone as soon as possible after the incident, preferably within 24-72 hours. Within two weeks of 

30 the incident, unless other arrangements have been made, the Permit Holder/PI must submit a written 

31 report that includes a complete description of the events surrounding the incident and identification of 

32 steps that will be taken to reduce the potential for additional incidents. 
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1 Mitigation for Exposure to Playbacks and Other Acoustic Research. A particular playback trial 

2 would be suspended if the exposed cetaceans show strong reactions, as indicated by sustained 

3 breaching and other activities commonly associated with stressed or agitated cetaceans. Other 

4 mitigation for this research would be included as conditions of the ESA/MMPA permit. 

5 Additional Mitigation for USFWS Marine Mammal Species. If sea otters, walrus, or manatees are 

6 injured or killed during research activities, research would be suspended. A report would be sent to 

7 the USFWS, Division of Management Authority, the appropriate USFWS Field Office, and NMFS 

8 PR1. 

9 5.2.6.3 Mitigation Measures for Other Biological Resources 

10 Measures would be taken to avoid protected and sensitive habitats during research projects. If 

11 activities would occur within the boundaries of a federally protected area, the appropriate personnel 

12 would be notified. Notification would include specific dates, locations, and participants involved in 

13 the activities. If necessary, permits would be obtained to conduct research in these areas. 

14 Nesting sea turtles and birds would be avoided during activities. If necessary, activities would be 

15 coordinated with the appropriate State agency/agencies to ensure there would be no adverse impacts. 

16 5.3 Water and Sediment Quality 

17 5.3.1 Stranding Agreements and Response Alternatives 

18 The SA template (Article III and Article IV, Part B, Number 4) would require SA holders to make 

19 every reasonable effort to assist in the clean-up of beach areas where their activities, such as necropsy 

20 or specimen collection, contributed to the soiling of the site. NMFS would develop spill prevention 

21 best management practices for responders to use to reduce the incidence of spills from equipment, 

22 euthanasia solution, etc. These measures would help protect the surrounding environment, including 

23 water and sediment quality. 

24 5.3.2 Carcass Disposal Alternatives 

25 Carcass burial on beaches and disposal in State waters would only occur after state and/or local 

26 authorities have given permission to conduct such activities. Stranding network members, in 

27 coordination with NMFS (if necessary), would obtain any permits necessary and follow any 

28 conditions or mitigation set forth in the permits. Approval from state and/or local authorities would 

29 ensure that impacts to water and sediment quality would be minimal. The SA template (Article III 
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Final Programmatic Environmental Impact Statement February 2009 

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1 and Article IV, Part B, Number 4) would require SA holders to make every reasonable effort to assist 

2 in the clean-up of beach areas where their activities, such as necropsy or specimen collection, 

3 contributed to the soiling of the site. These measures would help protect the surrounding 

4 environment, including water and sediment quality. 

5 If carcasses are known or assumed (based upon test results or prior knowledge of the species) to have 

6 contaminant levels that meet or exceed the definition of hazardous waste under EPA, state, and/or 

7 local regulations, they would be taken to an EPA-designated hazardous waste landfill for proper 

8 disposal. 

9 Non-toxic carcasses may be disposed in Federal waters without a permit. Disposal of carcasses that 

10 are known to be hazardous waste at sea may require EPA approval and a permit. These carcasses 

11 would be disposed of in an EPA designated ocean dumping site. All EPA dumping sites are managed 

12 to avoid or minimize impacts to the marine environment. Materials used to sink carcasses would be 

13 chosen to avoid or minimize any impacts to the marine environment. 

14 5.3.3 Rehabilitation Activities Alternatives 

15 Rehabilitation facilities would have any required NPDES, state, and local permits, for facility 

16 discharges directly to surface waters. Facilities discharging to POTWs would have any necessary 

17 effluent discharge permits and a pretreatment plan in place to meet municipal wastewater treatment 

18 standards. Water used in temporary pools would be discharged into a sewer drain, where available, 

19 and would be taken to a wastewater treatment plant. No mitigation measures are in place for water 

20 drainage into nearshore waters or the use of net pens. The development of a monitoring plan is 

21 recommended to determine impacts and potential mitigation measures. 

22 5.3.4 Release of Rehabilitated Animals Alternatives 

23 If hazardous materials or wastes were discharged during release activities, stranding network 

24 members would notify the appropriate Federal, state, or local authorities. 

25 5.3.5 Disentanglement Alternatives 

26 If hazardous materials or wastes were released during disentanglement activities, responders would 

27 notify the appropriate Federal, state, or local authorities. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

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1 5.3.6 Biomonitoring and Research Alternatives 

2 If hazardous materials or wastes were released during biomonitoring and research activities, 

3 personnel would notify the appropriate Federal, state, or local authorities. 

4 5.4 Cultural Resources 

5 5.4.1 Stranding Agreements and Response Alternatives 

6 Under Alternatives A2, A3, A4, and A5, potential damage to cultural resources during stranding 

7 response may be avoided by contacting the appropriate SHPO or other local authorities prior to any 

8 major land disturbance. Known cultural resources would be avoided during transport and removal 

9 activities. If cultural resources are discovered during response operations, all work would cease and 

10 the SHPO would be contacted. 

11 Stranding response on Native American/Alaska Native lands would be coordinated with the Tribal 

12 Historic Preservation Officer (THPO), Native American tribes, Alaska Natives, or other aboriginal 

13 peoples to accommodate cultural uses of marine mammals. Responders would also be sensitive to the 

14 fact that tribal cultures often involve ceremonial, medicinal, or subsistence uses or plants, animals 

15 (including marine mammals), and specific geographic locations. These measures would be taken to 

16 minimize or eliminate any potential impacts on Alaska Natives, Native American tribes, or other 

17 aboriginal people’s cultural uses of coastal resources. 

18 The SA template (Article III and Article IV, Part B, Number 4) would require SA holders to make 

19 every reasonable effort to assist in the clean-up of beach areas where their activities, such as necropsy 

20 or specimen collection, contributed to the soiling of the site. These measures would help protect the 

21 surrounding environment, which may include undiscovered cultural resources. 

22 5.4.2 Carcass Disposal Alternatives 

23 Under Alternatives B2 and B3, potential damage to cultural resources would be avoided by contacting 

24 the appropriate SHPO or other local authorities before selecting a beach burial site. The proximity of 

25 cultural resources to a site may change the method of carcass disposal, if necessary. Known cultural 

26 resources would be avoided during transport and removal activities. If cultural resources are 

27 discovered during burial operations, all work would cease and the SHPO would be contacted. 

28 Carcass disposal on Native American/Alaska Native lands would be coordinated with the THPO, 

29 Native American tribes, Alaska Natives, or other aboriginal peoples to accommodate cultural uses of 
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Final Programmatic Environmental Impact Statement February 2009 

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1 marine mammals. Responders would also be sensitive to the fact that tribal cultures often involve 

2 ceremonial, medicinal, or subsistence uses or plants, animals (including marine mammals), and 

3 specific geographic locations. These measures would be taken to minimize or eliminate any 

4 potential impacts on Alaska Natives, Native American tribes, or other aboriginal people’s cultural 

5 uses of coastal resources. 

6 5.4.3 Rehabilitation Activities Alternatives 

7 If cultural resources are discovered during activities under Alternatives C2 and C3, all activities 

8 would cease and the SHPO/THPO would be contacted. Known cultural resources would be avoided 

9 during rehabilitation activities. 

10 5.4.4 Release of Rehabilitated Animals Alternatives 

11 If cultural resources are discovered during release activities under Alternatives D2 and D3, all 

12 activities would cease and the SHPO/THPO would be contacted. Known cultural resources would be 

13 avoided during release activities. 

14 5.4.5 Disentanglement Alternatives 

15 No mitigation measures are necessary, as impacts would not be expected under the disentanglement 

16 alternatives. 

17 5.4.6 Biomonitoring and Research Alternatives 

18 Under Alternatives F2 and F3, impacts to cultural resources during biomonitoring and research 

19 activities would be avoided by contacting the appropriate SHPO/THPO or other local authorities prior 

20 to any projects that may disturb or damage resources. Known cultural resources would be avoided 

21 during research activities. If cultural resources are discovered during these activities, all work would 

22 cease and the SHPO/THPO would be contacted. 

23 5.5 Human Health and Safety 

24 5.5.1 Stranding Agreements and Response Alternatives 

25 For Alternatives A4 and A5, the SA template (Article II, Part C, Number 5) recommends Stranding 

26 Network participant organizations to take precautions against injury or disease to any network 

27 personnel, volunteers, and the general public when working with live or dead marine mammals. The 

28 SA template also requires the stranding network participant to notify the NMFS Regional coordinator 
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Final Programmatic Environmental Impact Statement February 2009 

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1 within 24 hours of detecting and/or confirming any zoonotic diseases in an animal which could affect 

2 human health. In addition, the SA template (Article III and Article IV, Part B, Number 4) would 

3 require SA holders to make every reasonable effort to assist in the clean-up of beach areas where their 

4 activities, such as necropsy or specimen collection, contributed to the soiling of the site. NMFS 

5 would develop spill prevention best management practices for responders to use to reduce the 

6 incidence of spills from equipment, euthanasia solution, etc. These measures would help protect the 

7 surrounding environment and public health. 

8 All SA holders engaged in stranding response would have a health and safety plan for personnel and 

9 volunteers that is presented to and reviewed by NMFS as part of their application for a new or 

10 renewal SA. Measures that may be utilized by SA holders to reduce health and safety risks during 

11 responses include, but are not limited to, the use of protective clothing, face protection, and eye 

12 protection. Other elements that may be included in a health and safety plan where feasible are: the use 

13 of life jackets and wet or dry suits during water responses; rotation of responders to minimize the 

14 amount of exposure and reduce fatigue; availability of first-aid kits and facilities for clean-up; and 

15 training for responders in first-aid and CPR. A proper first-aid kit and a person trained in the 

16 treatment of drug accidents should be present if etorphine or paralytic agents are used for euthanasia. 

17 Risks from the consumption of marine mammal meat would be reduced by continuing to inform 

18 Alaska Natives on the potential for contaminants and disease. This is currently done by NMFS 

19 through the co-management process with Alaska Natives. 

20 Marine mammal oil spill response guidelines have been developed for the MMHSRP (Appendix L). 

21 The guidelines would serve as mitigation for impacts under Alternatives A2, A3, A4, and A5. 

22 Personnel involved in spill response activities would have to comply with all applicable worker health 

23 and safety laws and regulations. The primary Federal regulations are the OSHA standards for 

24 Hazardous Waste Operations and Emergency Response (HAZWOPER) (29 CFR 1910.120). Oil spill 

25 response personnel may be required to have HAZWOPER training, depending on the extent of their 

26 involvement and state regulations. Recommended training for response includes first-aid, Cardio 

27 Pulmonary Resuscitation (CPR), the Incident Command System (ICS), aircraft and boating safety, 

28 and general oil spill response. Recommended personal protective equipment includes full eye 

29 protection, oil resistant clothing, gloves, ear protection, and respiratory protection. The Material 

30 Safety Data Sheet (MSDS) for the spilled material would be reviewed and all recommended 

31 precautions would be followed. Response personnel would be periodically monitored to determine 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

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1 exposure. Marine mammal stranding network members would be responsible for training and 

2 certifying their employees and volunteers. 

3 5.5.2 Carcass Disposal Alternatives 

4 For Alternatives B2 and B3, the SA Template (Article II, Part C, Number 5) recommends Stranding 

5 Network participant organizations to take precautions against injury or disease to any network 

6 personnel, volunteers, and the general public when working with live or dead marine mammals. The 

7 SA template also requires the Stranding Network participant to notify the NMFS Regional 

8 coordinator within 24 hours of detecting and/or confirming any diseases of concern in an animal 

9 which could affect human health. Response workers would be required to have sufficient protection 

10 against infection with zoonotic pathogens, contaminants, and other risks associated with handling 

11 decomposing carcasses. Workers would be required to wear, as necessary, protective clothing, 

12 gloves, face masks and safety goggles. Equipment used to move and dispose of carcasses would be 

13 cleansed and disinfected to reduce the risk of zoonotic pathogens or other possible contaminants. The 

14 marine mammal oil spill response guidelines (Appendix L) would serve as mitigation for impacts 

15 under Alternatives B2 and B3. These mitigation measures would be the same as those discussed 

16 above for oil spill response to stranded animals. 

17 The burial or disposal at sea (in state waters) of a carcass would only occur after state and/or local 

18 authorities have given permission to conduct such activities. Stranding network members would 

19 obtain any permits necessary to conduct carcass burial on beaches or other suitable locations and 

20 disposal in state waters. This would include any permits or coordination with the State’s health 

21 department, to ensure that public health and safety would be protected. 

22 5.5.3 Rehabilitation Activities Alternatives 

23 For Alternatives C3 and C4, the SA template (Article II, Part C, Number 5) recommends Stranding 

24 Network participant organizations to take precautions against injury or disease to any network 

25 personnel, volunteers, and the general public when working with live or dead marine mammals. The 

26 SA template also requires the stranding network participant to notify the NMFS Regional coordinator 

27 within 24 hours of detecting and/or confirming any diseases of concern in an animal which could 

28 affect human health. The implementation of the Rehabilitation Facility Standards would also serve as 

29 mitigation for Alternatives C3 and C4. Section 10 of the standards would require health and safety 

30 plans that identify all of the safety issues that may be a factor when working closely with wild marine 

31 mammals. Plans would include specific information for the direct handling of all species seen at the 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

5-22 

1 facility. Personnel would be trained to identify potential zoonotic diseases and prevent their 

2 transmission from animal to human. Staff would be trained to properly handle contaminated 

3 equipment and proper sanitation techniques (Section 4). 

4 Rehabilitation facilities would follow OSHA regulations regarding personnel protective equipment 

5 (29 CFR 1910, subpart I). Safety equipment would be provided, including eye protection, protective 

6 clothing, and eye flushing stations. OSHA regulations (29 CFR 1910, subpart D) provide measures to 

7 reduce slips, falls, and other physical injuries in the workplace. Protocols for appropriate handling of 

8 chemicals would be available, including all MSDS. Hazardous materials and toxic substances would 

9 be handled and stored according to OSHA regulations (29 CFR 1910, subpart H and subpart Z). A 

10 proper first-aid kit and a person trained in the treatment of drug accidents would be present if 

11 etorphine or paralytic agents were used for euthanasia. 

12 The marine mammal oil spill response guidelines would serve as mitigation for impacts under 

13 Alternatives C2, C3, and C4. Personnel involved in the rehabilitation of oiled marine mammals 

14 should have HAZWOPER training. Training on the ICS, first-aid, CPR, crisis management, marine 

15 mammal oil spill response, and hazard communication are recommended. Recommended personal 

16 protective equipment includes full eye protection, oil resistant clothing, gloves, ear protection, and 

17 respiratory protection. The MSDS for the spilled material would be reviewed and all recommended 

18 precautions would be followed. Rehabilitation personnel and facilities would be periodically 

19 monitored to determine exposure. Facilities would have adequate ventilation to protect against the 

20 toxic effects of volatile agents. Marine mammal stranding network members would be responsible 

21 for training and certifying their employees and volunteers. 

22 5.5.4 Release of Rehabilitated Animals Alternatives 

23 For Alternatives D2 and D3, the SA template (Article II, Part C, Number 5) recommends Stranding 

24 Network participant organizations to take precautions against injury or disease to any network 

25 personnel, volunteers, and the general public when working with live marine mammals. Under 

26 Alternatives D2 and D3, all SA holders involved in the release of rehabilitated animals would have a 

27 health and safety plan. All release personnel would be trained appropriately to avoid or minimize 

28 health and safety hazards. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

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1 5.5.5 Disentanglement Alternatives 

2 Under Alternatives E2 and E3, safety measures utilized by responders would include immersion suits, 

3 life jackets, helmets, and a small closed knife that is available to cut lines and gear in an emergency 

4 situation. Typically, a standby vessel (usually a USCG or NOAA vessel) would accompany the 

5 responders in case additional assistance is required. Experienced responders would not attempt 

6 disentanglement, or would end an attempt, if it was too dangerous. Under Alternative E2, training 

7 would be required for East Coast responders in order to be certified for disentanglement. Under 

8 Alternative E3, training would be required for responders nationwide in order to be certified for 

9 disentanglement. Training would depend upon their level of involvement (see Appendix C, 

10 Disentanglement Guidelines). The appropriate training would ensure that responders know the 

11 potential safety risks and the methods to avoid or minimize these risks. While these safety measures 

12 may reduce some risks, there would always be potential for adverse effects on human health and 

13 safety. 

14 5.5.6 Biomonitoring and Research Alternatives 

15 Safety protocols have been developed for health assessment studies. The use of life vests would be 

16 required, in order to comply with NOAA’s Small Boat Safety Program and policies (NAO 209-125). 

17 Gloves and other protective clothing would be used during sampling. Gloves and protective eyewear 

18 would be required during the use of liquid nitrogen. It is recommended that at least one emergency 

19 medical technician would be present for health assessment activities conducted in water or offshore. 

20 If possible, USCG personnel would accompany the research vessels to assist in an emergency and to 

21 keep other vessels away from the site. 

22 Health and safety plans would be developed for all permitted research actions. Only experienced 

23 personnel would be conducting research, which would reduce health and safety risks. NOAA’s Small 

24 Boat Safety Program and policies (NAO 209-125) and policies on NOAA employees on non-NOAA 

25 vessels (NAO 209-115, as applicable) would be followed to reduce risks during vessel operations. 

26 NOAA’s Aviation Safety Policy (NAO 209-124) would be followed to minimize hazards during 

27 aircraft operations. 

28 For diagnostic testing and specimen analyses, each individual laboratory should have a Chemical 

29 Hygiene Plan, as described in 29 CFR 1910.1450. A Chemical Hygiene Plan would contain work 

30 practices, policies, and procedures that ensure a safe environment. Researchers would receive 

31 training on the hazards of chemicals used in the laboratory and be provided with the proper 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

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1 equipment for their safe handling, including respiratory protection. These measures would eliminate 

2 most of the risks associated with laboratory work. 

3 5.6 Socioeconomics 

4 5.6.1 Stranding Agreements and Response Alternatives 

5 Stranding network members may be able to use available funds from the Prescott Grant Program to 

6 help offset costs incurred by response activities. 

7 5.6.2 Carcass Disposal Alternatives 

8 Stranding network members may be able to use available funds from the Prescott Grant Program to 

9 help offset costs incurred by carcass disposal activities. 

10 5.6.3 Rehabilitation Activities Alternatives 

11 To minimize the impacts of implementing the Rehabilitation Facility Standards, NMFS would 

12 provide a reasonable process for facilities to be upgraded to meet the minimum standards. 

13 Substandard facilities may be improved using funds that may be available through the Prescott Grant 

14 Program. Prescott funds may also be used to improve facilities that meet the minimum standards, 

15 with the goal to achieve or exceed the recommended standards. 

16 5.6.4 Release of Rehabilitated Animals Alternatives 

17 Stranding network members may be able to use available funds from the Prescott Grant Program to 

18 help offset costs incurred by release activities. 

19 5.6.5 Disentanglement Alternatives 

20 Disentanglement training expenses would be covered by the MMHSRP. This would eliminate most 

21 expenses associated with training. 

22 5.6.6 Biomonitoring and Research Alternatives 

23 Some biomonitoring and research expenses would be covered by the MMHSRP, eliminating some of 

24 the socioeconomic impact to personnel. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

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1 6. Cumulative and Other Impacts 

2 6.1 Resource Specific Cumulative Impact Analysis 

3 A cumulative impact is defined as the incremental impact of the Proposed Actions and alternatives 

4 when added to past, present, and reasonably foreseeable actions. Reasonably foreseeable future 

5 actions consist of activities that have been approved and can be evaluated with respect to their 

6 impacts. Cumulative impacts can result from individually minor, but collectively significant, actions 

7 occurring over a period of time. 

8 The cumulative impacts analysis considers past, present, and planned or reasonably foreseeable 

9 programs and projects that could affect each resource area and may add to the incremental impacts of 

10 the Proposed Actions and alternatives in the action area. Because the size of the action area is 

11 extensive, local projects will not be analyzed; instead general threats to each resource area will be 

12 analyzed. Future, reasonably foreseeable MMHSRP actions that are not fully analyzed in the PEIS are 

13 listed in Table 6-1. For the purposes of this PEIS, only those resources identified in Section 3.0 that 

14 might be impacted by the Proposed Actions and alternatives will be discussed in this section. 

15 Table 6-1. Reasonably Foreseeable MMHSRP Actions 

MMHSRP Action Description Timeline 

Standards for 

Rehabilitation 

Facilities/Release 

Criteria 

Currently, these standards and criteria can only be implemented 

as guidelines. A proposed rule would be written to make these 

into regulations for all future rehabilitation facilities and 

activities. At a minimum, an EA would be prepared to assess 

any impacts associated with the proposed rule that have not 

been addressed in this PEIS, including a Regulatory Impact 

Review. 

1-2 years 

(after release 

of this PEIS) 

Rehabilitation 

Facility Inspection 

Program 

The NMFS’ MMHSRP has an interagency agreement with 

APHIS to plan and possibly implement an inspection program 

for rehabilitation facilities, based upon the Standards for 

Rehabilitation Facilities. 

2008-2009 

Public Viewing 

Guidelines 

Public viewing at rehabilitation facilities is only allowed under 

MMPA regulations (50 CFR 216.27 (c)(5)) if the NMFS 

Regional Director or the NMFS Office of Protected Resources 

Director has specifically authorized the activities and they are 

conducted in a matter consistent with the requirements 

applicable to public display. Public viewing guidelines would be 

developed by NMFS and may be included in the Rehabilitation 

Facility Standards and any associated regulations. At a 

minimum, an EA would be prepared to assess any impacts 

associated with the proposed guidelines. 

Undetermined
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

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Table 6-1. Reasonably Foreseeable MMHSRP Actions (continued) 

MMHSRP Action Description Timeline 

Human Interaction 

Handbook and 

Data Sheet 

A human interaction handbook and data sheet will undergo 

necessary clearance procedures and will be used by the National 

Stranding Network. 

2009 

Workshop on 

Candidates for 

Rehabilitation 

The NMFS’ MMHSRP will hold a workshop regarding 

decisionmaking during response activities to determine animals 

that are good rehabilitation candidates. Guidelines to determine 

good rehabilitation candidates would be developed. 

2009 

Disentanglement 

Network- Use of 

Divers in Water 

A workshop is being planned regarding the use of divers for 

disentanglement activities. The workshop attendees would 

include national and international professionals involved in 

disentanglement activities. 

2009 

Research on 

Humane Chemical 

Euthanasia 

NMFS will continue to support and fund research on humane 

methods of chemical euthanasia. This includes research 

regarding the environmental impacts of chemical euthanasia 

solutions. 

Continuous 

1 

2 6.1.1 Biological Resources 

3 The response, rehabilitation, and release activities of the MMHSRP would have a beneficial 

4 cumulative effect on marine mammals. The MMHSRP would continue to rehabilitate and return 

5 animals to the wild that would have died otherwise. Returning threatened and endangered animals 

6 back to the wild would have a large impact on the survival of these species. With the implementation 

7 of the release criteria, the threat of releasing diseased animals would be eliminated or minimized. 

8 Without the release criteria, a potential cumulative adverse impact could occur if diseased animals 

9 were released and infected wild populations. The MMHSRP, combined with other NMFS activities, 

10 would have beneficial cumulative impacts on all marine mammals. Other NMFS activities include: 

11 the North Atlantic Right Whale Ship Strike Reduction Strategy; Marine Mammal Conservation Plans; 

12 ESA Recovery Plans; Take Reduction Plans; and issuance of incidental harassment authorizations, 

13 Incidental harassment authorizations require implementation of mitigation so that activities that may 

14 unintentionally take marine mammals are subject to standards that achieve a negligible impact on 

15 species or stocks and the least practicable adverse effect on marine mammals. 

16 Research activities of the MMHSRP, combined with all other past, present, and future marine 

17 mammal research authorized by permits from the NMFS PR1, could have cumulative adverse impacts 

18 on marine mammals. All research activities include takes of marine mammals. Activities have the 

19 potential to interrupt mating, feeding, and diving behaviors as well as injure or kill animals. Takes 

20 may be occurring on the same individual or group of animals and could be disrupting essential 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

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1 behaviors. NMFS PR1 currently has 193 scientific research and enhancement permits issued for 

2 marine mammals. Of these permits, 35 are general authorizations for Level B Harassment (Swails 

3 pers.comm.). However, the MMHRSP activities and other permitted research activities could result 

4 in cumulative beneficial impacts on marine mammals. The information gained from these activities 

5 may lead to ways to protect and conserve all marine mammals and increase those animals that are 

6 declining. 

7 The Standards for Rehabilitation Facilities and release criteria cannot be enforced unless they are 

8 incorporated into regulations. These regulations would have beneficial cumulative impacts on marine 

9 mammals. By law, Stranding Network participants would have to adhere to these regulations. 

10 Participants who are in violation of these regulations could be put on probation, suspended, or have 

11 their SA terminated, according to the Final SA Criteria (Appendix C). The rehabilitation facility 

12 regulations would ensure that rehabilitated animals would have the appropriate veterinary care in a 

13 healthy environment, maximizing the success rate of rehabilitation. The release criteria regulations 

14 would ensure that only healthy animals are released back to the wild, minimizing potential impacts to 

15 the wild population and ensuring a better survival rate for the released animal. 

16 The Rehabilitation Facility Inspection program would complement the rehabilitation facility 

17 regulations. Facilities would be inspected to ensure compliance with the regulations. NMFS would 

18 send a qualified individual to each rehabilitation facility to document existing facilities and to advise 

19 each facility of their areas of weakness. Once the Standards have been approved, inspections will be 

20 carried out on a rotating 1-3 year interval to ensure compliance. This program along with other 

21 MMHSRP activities would have beneficial cumulative impacts on marine mammals. 

22 Currently, public viewing of animals in rehabilitation is only allowed under MMPA regulations (50 

23 CFR 216.27(c)(5)) if the NMFS Regional Director or the NMFS Office of Protected Resources 

24 Director has specifically authorized the activities and they are conducted in a matter consistent with 

25 the requirements applicable to public display. NMFS would clarify the definition of public viewing 

26 for animals undergoing rehabilitation in 50 CFR 216.27(c)(5) to differentiate it from permanently 

27 captive animals on public display. NMFS would establish guidelines that govern when public 

28 viewing of rehabilitating marine mammals would be authorized. NMFS would work with APHIS to 

29 develop public viewing guidelines that ensure the requirements of the MMPA and the Animal 

30 Welfare Act are met. The guidelines would be designed to protect animal health and to ensure that 

31 the potential for a successful rehabilitation would not be compromised. At a minimum, an EA would 

32 be prepared to assess any impacts associated with the proposed guidelines. The guidelines would be 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

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1 available for review by the MMC, current rehabilitation facilities, and the public. Significant 

2 cumulative effects on marine mammals would not be expected from this activity. 

3 The NMFS’ MMHSRP will hold a workshop regarding decisionmaking during response activities to 

4 determine which animals are good rehabilitation candidates. Guidelines would be developed for 

5 stranding responders to use to determine good rehabilitation candidates on the beach. These 

6 guidelines would minimize the number of animals brought into rehabilitation facilities that are poor 

7 candidates for successful rehabilitation and release. The workshop would also address criteria for 

8 making immediate disposition determinations (e.g., beach release and relocation and release). 

9 Cumulative effects on marine mammals would not be expected from this activity. 

10 A human interaction handbook and data sheet have been developed by the Cape Cod Stranding 

11 Network and the Virginia Aquarium Stranding Response Team. These documents will undergo 

12 necessary clearance procedures and be used by the National Stranding Network. These materials will 

13 be used to provide stranding network personnel with the tools needed to evaluate marine mammals 

14 for signs of human interaction and to collect human interaction data consistently in all NMFS 

15 jurisdictional regions. Cumulative effects on marine mammals would not be expected from this 

16 activity. 

17 6.1.2 Water and Sediment Quality 

18 The MMHSRP’s activities would not likely add to the cumulative effects on water and sediment 

19 quality from other activities. Sewage outfalls, agricultural runoff, stormwater runoff, industrial 

20 operations, shipping operations, and coastal development all have an effect on water and sediment 

21 quality. The potential impacts from the MMHSRP’s activities would be negligible compared to these 

22 impacts. 

23 6.1.3 Cultural Resources 

24 For the preferred alternatives, the adoption of mitigation measures that would include contact with the 

25 appropriate SHPO, where warranted, and special release considerations for ice seals, the MMHSRP’s 

26 activities would be expected to have only minor potential for impacts on cultural resources, and 

27 would not incrementally contribute to a cumulatively significant impact to these resources. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

6-5 

1 6.1.4 Human Health and Safety 

2 Currently, public viewing of animals in rehabilitation is only allowed under MMPA regulations (50 

3 CFR 216.27 (c)(5)) if the NMFS Regional Director or the NMFS Office of Protected Resources 

4 Director has specifically authorized the activities and they are conducted in a matter consistent with 

5 the requirements applicable to public display. NMFS would establish guidelines that govern when 

6 public viewing of rehabilitating marine mammals would be authorized. At a minimum, an EA would 

7 be prepared to assess any impacts associated with the proposed guidelines. The guidelines would be 

8 designed to protect human health; therefore significant cumulative effects on public health and safety 

9 would not be expected. 

10 The MMHSRP is in the process of planning a workshop to discuss the use of divers in the water 

11 during disentanglement activities. The workshop would likely be held sometime in 2007. Workshop 

12 attendees will include national and international professionals involved with disentanglement. Other 

13 countries have used divers to disentangle animals and the workshop will discuss the potential ways 

14 this could be implemented in the U.S. If the Disentanglement Network would decide to use divers in 

15 the water, a major amendment to the MMHSRP’s ESA/MMPA permit would be necessary. This 

16 would require at minimum, an EA to analyze the impacts on human health and safety, biological 

17 resources, and any other resource that may be affected. 

18 6.1.5 Socioeconomics 

19 The Rehabilitation Facility Standards and release criteria cannot be enforced unless they are 

20 incorporated into regulations. The PEIS has taken a general look at potential impacts of requiring 

21 rehabilitation facilities to comply with the standards. However, at minimum, an EA would be 

22 necessary to fully assess the socioeconomic impacts of making these standards into regulations. An 

23 EA would be prepared to assess any impacts associated with the proposed rule that have not been 

24 addressed in this PEIS, including a Regulatory Impact Review. This action is anticipated to happen 

25 within one to two years after the release of this PEIS. 

26 Release of pinnipeds on the West Coast could have an adverse cumulative impact. Pinniped conflicts 

27 with commercial and recreational fisheries are ongoing. California sea lions and harbor seals remove 

28 catch and damage gear in all types of fisheries, including gillnet, purse seine, trap and live bait 

29 fisheries. Along the West Coast, seals and sea lions have taken threatened and endangered salmon 

30 passing through the fish ladders. The conflict has resulted in economic losses for some commercial 

31 fisheries and impaired the recovery of salmon stocks. Recreational fishers frequently move their 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

6-6 

1 boats when sea lions are present, and incur additional fuel costs and loss of fishing time. The release 

2 of pinnipeds would add individuals to already growing populations and could contribute to an 

3 increase in interactions with the commercial and recreational fisheries, causing more economic losses. 

4 Space conflicts between pinnipeds and humans have occurred at harbors and beaches, such as 

5 Children’s Pool in La Jolla, California. More animals hauled out on beaches may deter beach 

6 visitors, and impact revenue gained from beachgoers. Currently no released pinnipeds have been 

7 documented in any of these conflicts. Released pinnipeds or their offspring could be involved in 

8 future conflicts, which may have an adverse cumulative impact on socioeconomics. 

9 The NMFS’ MMHSRP will hold a workshop regarding decisionmaking during response activities to 

10 determine animals that are good rehabilitation candidates. Guidelines would be developed for 

11 stranding responders to use to determine good rehabilitation candidates on the beach. These 

12 guidelines would minimize the number of animals brought into rehabilitation facilities that are poor 

13 candidates for successful rehabilitation and release. This action would likely reduce expenditures of 

14 resources on non-releasable animals and may be a beneficial impact for rehabilitation facilities. 

15 6.2 Unavoidable Adverse Impacts 

16 Unavoidable adverse impacts on marine mammals would occur from the MMHSRP’s activities. 

17 During response and rehabilitation activities, animals may still exhibit adverse reactions, sustain 

18 injuries or die, despite the best efforts made by Stranding Network participants and the proposed 

19 mitigation measures. Disentanglement activities would always require a vessel close approach, which 

20 may produce adverse reactions from animals. However, these activities would be conducted to help 

21 animals, and the long-term beneficial impacts would outweigh the short-term adverse impacts. 

22 Research activities would impact marine mammals even with the proposed mitigation measures. 

23 Animals may have adverse reactions to research activities, or may be injured or die despite the use of 

24 best available science and techniques. 

25 Unavoidable impacts on human health and safety would occur from the MMHSRP’s activities. Even 

26 with the proposed mitigation measures, there would still be a risk to marine mammal personnel safety 

27 and public safety. Some risk would always be present when working with wild animals, as their 

28 behavior is unpredictable. Disentanglement activities would always be dangerous, due to animal 

29 behavior and working on the open ocean. Public safety would be impacted, as there would be a lag 

30 time between when an animal is reported and when a Stranding Network participant gets to the scene. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

6-7 

1 Between this time, people could still come in contact with the animal, risking physical injuries or 

2 potential zoonotic diseases. 

3 6.3 Irreversible and Irretrievable Commitment of Resources 

4 Irreversible commitments of resources are actions which disturb either a non-renewable resource or a 

5 renewable resource to the point that it can only be renewed over a long period of time (i.e. decades). 

6 Irretrievable commitments are losses of resources that occur for a shorter period of time. For the 

7 alternatives, most resource commitments are neither irreversible nor irretrievable. Many potential 

8 adverse impacts are short-term and temporary. Others may have a longer effect that can be reduced 

9 through the proposed mitigation measures in Section 5. 

10 6.4 Relationship Between Short-term Uses and Long-term 

11 Productivity 

12 This NEPA required consideration addresses the question of whether the alternatives would be 

13 providing short-term benefits at the cost of future generations. Based on the analyses presented under 

14 Section 4, Environmental Consequences, no long-term loss of productivity would be expected. The 

15 MMHSRP’s response, rehabilitation, release, and research activities would contribute to the long16 term productivity of marine mammals. 

17 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

7-1 

7. Preparers 

Sarah Howlett 

Fishery Biologist 

Office of Protected Resources 

National Marine Fisheries Service/NOAA 

Silver Spring, MD 

M.M.A. Marine Affairs 

B.S. Environmental Resource Management 

Michelle McGregor 

Economist 

Office of Protected Resources 

National Marine Fisheries Service/NOAA 

Silver Spring, MD 

Ph.D. Agricultural Economics 

B.S. Zoology and Economics 

Janet Whaley 

National Stranding Coordinator 

Office of Protected Resources 

National Marine Fisheries Service/NOAA 

Silver Spring, MD 

Doctor of Veterinary Medicine 

B.S. Biology 

Sarah Wilkin 

Fishery Biologist 

Protected Resources Division 

Southwest Regional Office 

National Marine Fisheries Service/NOAA 

Long Beach, CA 

M.S. Marine Science 

B.S. Marine Science 
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9-1 

9. Glossary 

Biotoxin- A poisonous substance produced by a living organism (e.g. brevetoxin, saxitoxin). 

Brucellosis- An infectious disease caused by the bacteria of the genus Brucella and may be passed to 

humans by contact with infected animals or animal products. Human symptoms include fever, 

sweats, headaches, back pain, and physical weakness. 

Caliciviruses- Marine mammals may have the calicivirus San Miguel Sea Lion Virus, which causes 

skin lesions (skin vesicles) in marine mammals and potential premature births. In humans, 

caliciviruses cause hepatitis, diarrhea, and hemorrhaging. 

Cetacean- A marine mammal of the order Cetacea, including whales, dolphins, and porpoises. 

Clostridium spp.- Large genus of Gram-positive bacteria with four main species that can cause 

diseases in humans. Food poisoning, gangrene, colitis, and death may result from infections. 

Conspecifics- Members of the same species. 

Critical habitat- Specific areas within the geographical area occupied by the species at the time of 

listing (under the ESA), if they contain physical or biological features essential to conservation, and 

those features may require special management considerations or protection; and specific areas 

outside the geographical area occupied by the species if the agency (USFWS or NMFS) determines 

that the area itself is essential for conservation. 

Delphinid- Marine mammals of the family Delphinidae, including the killer whale (Orcinus orca), 

bottlenose dolphin (Tursiops truncatus), and the long-finned pilot whale (Globicephala melas). 

Depleted species- Defined by the MMPA as any case in which: (a) the Secretary of Commerce, after 

consultation with the Marine Mammal Commission and the Committee of Scientific Advisors on 

Marine Mammals, determines that a species or population stock is below its optimum sustainable 

population; (b) a State determines that such species or stock is below its optimum sustainable 

population; or (c) a species or population stock is listed as a threatened species or endangered species 

under the ESA. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

9-2 

Distinct Population Segment (DPS)- A vertebrate population or group of populations that is discrete 

from other populations of the species and significant in relation to the entire species. Distinct 

population segments may be listed as threatened or endangered under the ESA. 

Endangered species- Defined under the ESA as “any species which is in danger of extinction 

throughout all or a significant portion of its range.” 

Endocarditis- Inflammation of the inner lining of the heart due to an infection. 

Epizootic- An outbreak of disease in an animal population. 

Erysipelothrix rhusiopathiae- A pathogenic bacteria that causes systemic disease which typically 

causes red, hard patches on the skin, with swelling and pain. More severe cases can result in acute 

septicemia and death. 

Essential Fish Habitat (EFH)- Defined under the Magnuson-Stevens Fishery Conservation and 

Management Act as waters and substrate that are necessary to the fish species for spawning, breeding, 

feeding, or growth to maturity. 

Etorphine (Immobilon®)- A powerful synthetic narcotic analgesic related to morphine used in 

veterinary medicine for tranquilizing large animals (e.g. elephants). It is a controlled class II drug 

under the Drug Enforcement Administration. 

Evolutionary Significant Unit (ESU)- A Pacific salmon population or group of populations that is 

substantially reproductively isolated from other conspecific populations and that represents an 

important component of the evolutionary legacy of the species. 

Exsanguination- The fatal process of total blood loss which may be used as a mode of euthanasia in 

marine mammals. 

Fomites- Substances that absorb, hold, and transport infectious disease agents

Gastroenteritis- Inflammation of the stomach and large and small intestines caused by a virus, 

resulting in vomiting or diarrhea. 

Giardiasis- A diarrheal illness caused by a one-celled, microscopic parasite, which lives in the 

intestines and is passed in the stool. It is found in drinking and recreational waters. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

9-3 

Harassment- Under the 1994 amendments to the MMPA, harassment is statutorily defined as any act 

of pursuit, torment, or annoyance which: has the potential to injure a marine mammal or marine 

mammal stock in the wild (Level A Harassment); or has the potential to disturb a marine mammal or 

marine mammal stock in the wild by causing disruption of behavioral patterns, including, but not 

limited to, migration, breathing, nursing, breeding, feeding, or sheltering but which does not have the 

potential to injure a marine mammal or marine mammal stock in the wild (Level B Harassment). 

Harmful algal bloom (HAB)- A diverse array of blooms of both microscopic and macroscopic 

marine algae which produce: toxic effects on humans and other organisms; physical impairment of 

fish and shellfish; nuisance conditions from odors and discoloration of waters or habitats. 

Humane- In the context of euthanasia is defined by the MMPA means “that method of taking which 

involves the least possible degree of pain and suffering practicable to the mammal involved.” 

Hyperthermia- An acute condition which occurs when the body produces or absorbs more heat than 

it can dissipate; also referred to as heat stroke or sunstroke. 

Hyponatremia- Low blood sodium. In marine mammals it is manifested by anorexia, followed by 

uncoordinated or spastic movements progressing to a generalized muscle quivering over the entire 

body, especially the flippers. 

Hypothermia- Condition in which body temperature drops below the level required for normal 

metabolism and/or bodily function to take place. 

Immunosuppression- State in which the ability of the body’s immune system to fight infections or 

disease is decreased. 

Leptospirosis- An infectious disease caused by the bacteria of the genus Leptospira that affects 

humans and animals. Causes tubular necrosis (kidney disorder) in marine mammals. Human 

symptoms include high fever, severe headache, muscle ache, chills, and vomiting. 

Morbillivirus- A highly contagious and lethal genus of virus (Family Paramyxoviridae) that has been 

responsible for more significant marine mammal die-offs due to infectious disease than any other 

pathogen to date. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

9-4 

Mycobacterium spp.- A genus of bacteria that includes many pathogens known to cause serious 

diseases. In marine mammals, may cause dermal abscesses and pulmonary tuberculosis (infection of 

the lungs). In humans, may cause skin lesions, pulmonary tuberculosis, and skin tuberculosis. 

Mycoplasma (Seal Finger)- Bacteria which may cause mycoplasmal pneumonia (infection of the 

lungs) in marine mammals. In humans, may cause skin lesions and infection may progress to 

arthritis, cellulitis (inflammation of the connective tissue of the skin), or tenosynovitis (inflammation 

of the fluid-filled sheath that surrounds the tendon). 

Mysticete- A whale that has baleen (plates of keratinized tissue that hang from the upper jaw) instead 

of teeth (suborder Mysticeti). Examples include the humpback whale (Megaptera novaeangliae), 

gray whale (Eschrichtius robustus), and minke whale (Balaenoptera acutorostrata). 

Odontocete- Toothed whales (suborder Odontoceti). Examples include the sperm whale (Physeter 

macrocephalus), beluga whale (Delphinapterus leucas), harbor porpoise (Phocoena phocoena), and 

bottlenose dolphin (Tursiops truncatus). 

Otariid- Sea lions and fur seals (family Otariidae). Examples include the Steller sea lion 

(Eumetopias jubatus) and the Northern fur seal (Callorhinus ursinus). 

Pathology- The scientific study of the nature of disease and its causes, processes, development, and 

consequences. 

Persistent Organic Pollutant (POP)- Chemicals that remain intact in the environment for long 

periods, become widely distributed geographically, accumulate in fatty tissue of living organisms, and 

are toxic to humans and wildlife. 

Phocid- True or earless seals (family Phocidae). Examples include the Hawaiian monk seal 

(Monachus schauinslandi), and the harbor seal (Phoca vitulina). 

Pinniped- Marine mammals in the suborder Pinnipedia with all four limbs modified into flippers, 

including seals, sea lions, and walruses. 

Polychlorinated Biphenyls (PCBs)- A group of toxic, carcinogenic organic compounds previously 

used for industrial purposes. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

9-5 

Polycyclic Aromatic Hydrocarbon (PAH)- Chemical compounds that consist of fused aromatic 

rings; many are known or suspected carcinogens. 

Rehabilitation- Treatment of beached and stranded marine mammals taken with the intent of 

restoring the marine mammal’s health and, if necessary, behavioral patterns. 

Salmonellosis- Infection caused by the bacteria Salmonella with symptoms including fever, 

abdominal cramps, and diarrhea. 

Seal poxvirus- Virus in pinnipeds which causes skin nodules which may ulcerate, spread rapidly, and 

persist for months. In humans, may cause swollen, red skin nodules. 

Septicemia- Disease caused by the spread of bacteria and their toxins in the bloodstream, also known 

as blood poisoning. 

Shigellosis- Disease caused by a group of bacteria (Shigella) with symptoms including diarrhea, 

fever, and stomach cramps 

Stranding- Defined under the MMPA as “an event in the wild in which (A) a marine mammal is 

dead and is (i) on a beach or shore of the United States; or (ii) in waters under the jurisdiction of the 

United States (including any navigable waters); or (B) a marine mammal is alive and is (i) on a beach 

or shore of the United States and is unable to return to the water; (ii) on a beach or shore of the United 

States and, although able to return to the water, is in need of apparent medical attention; or (iii) in the 

waters under the jurisdiction of the United States (including any navigable waters), but is unable to 

return to its natural habitat under its own power or without assistance.” 

Take- Defined under the MMPA as “to harass, hunt, capture, kill or collect, or attempt to harass, 

hunt, capture, kill or collect.” Defined under the Endangered Species Act as “to harass, harm, pursue, 

hunt, shoot, wound, kill, trap, capture, or collect, or attempt to engage in any such conduct.” 

Threatened species- Defined under the Endangered Species Act as “any species which is likely to 

become an endangered species within the foreseeable future throughout all or a significant portion of 

its range.” 

Unusual mortality event (UME)- Defined under the Marine Mammal Protection Act as “a stranding 

that is unexpected; involves a significant die-off of any marine mammal population; and demands 

immediate response.” 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

9-6 

West Nile Virus- Virus spread by mosquitoes that causes encephalitis (inflammation/swelling of the 

brain). 

Zoonotic- Any infectious disease that can be transmitted from animals to humans. 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

10-1 

10. Index

Alternative A1, 4-46 

Atlantic white-sided dolphin, 3-17 

Bearded seals, 3-41 

Beluga whale, 3-29, 3-30, 3-41, 9-4 

Blue whale, 2-2, 3-10, 3-11, 3-12, 3-17, 3-20, 

3-23, 3-26, 3-29, 4-34 

Bottlenose dolphin, 1-2, 3-17, 3-18, 3-20, 3-

21, 3-22, 3-23, 3-33, 4-30, 8-9, 9-1, 9-4 

Bowhead whale, 3-29, 3-31, 3-41 

California sea lion, 3-23, 3-24, 3-26, 6-5 

Carcass disposal, 2-1, 2-4, 2-5, 2-6, 3-30, 4-2, 

4-3, 4-11, 4-12, 4-14, 4-15, 4-41, 4-52, 4-

61, 4-67, 5-3, 5-17, 5-22 

burial, 2-7, 2-15, 3-42, 4-12, 4-13, 4-14, 4-

41, 4-47, 4-67, 5-3, 5-15, 5-17, 5-20 

composting, 2-5, 2-6, 4-12, 4-42 

incinerating, 2-5, 2-7, 4-42, 4-62 

landfill, 2-5, 2-6, 2-7, 4-15, 4-42, 4-52, 4-

62, 5-3, 5-15 

rendering, 2-5, 2-7, 4-12, 4-42, 4-52, 4-62 

cetacean, 3-14, 3-17, 3-19, 3-21, 3-22, 3-24, 3-

27, 3-30, 3-33, 4-6, 4-26, 4-55, 4-63, 5-8, 5-

9, 5-11, 5-12 

Convention on International Trade in 

Endangered Species of Wild Fauna and 

Flora (CITES), 1-10, 5-10 

Critical habitat, 3-2, 3-3, 3-7, 3-10, 3-11, 3-12, 

3-13, 3-23, 3-26, 3-29 

Endangered species, 1-8, 1-9, 1-10, 2-2, 2-4, 

2-8, 2-15, 3-1, 3-2, 3-3, 3-4, 3-5, 3-6, 3-7, 3-

9, 3-10, 3-11, 3-12, 3-13, 3-17, 3-20, 3-23, 

3-26, 3-29, 3-33, 4-2, 4-3, 4-5, 4-11, 4-14, 

4-15, 4-16, 4-19, 4-24, 4-26, 4-27, 4-60, 4-

67, 4-68, 5-3, 5-9, 6-2, 6-5, 9-1, 9-2, 9-5 

Endangered Species Act (ESA), 1-8, 1-9, 

 1-10, 1-12, 1-14, 1-15, 2-1, 2-2, 2-3, 2-6, 2-

11, 2-12, 2-13, 2-14, 3-3, 3-4, 3-5, 3-6, 3-

42, 4-3, 4-11, 4-61, 4-63, 4-68, 5-2, 5-3, 5-

5, 5-7, 5-8, 5-9, 5-10, 5-14, 6-2, 6-4, 9-1, 9-

2, 9-5 

Essential Fish Habitat (EFH), 1-14, 3-5, 9-2 

Euthanasia, 1-4, 1-10, 2-1, 2-5, 2-15, 2-16, 3-

44, 3-45, 3-46, 4-8, 4-9, 4-13, 4-16, 4-28, 4-

39, 4-40, 4-41, 4-42, 4-43, 4-51, 4-53, 4-54, 

4-66, 4-67, 4-68, 5-2, 5-5, 5-9, 5-19, 5-21, 

9-2, 9-3 

Evaluation Criteria for Marine Mammal 

Stranding Agreements, 2-4, 6-3 

Fin whale, 3-17, 3-18, 3-23, 3-26, 3-27, 3-29, 

3-30, 3-33, 4-7, 4-25, 4-29, 4-34, 4-54 

Gray seal, 3-17, 3-18, 3-20 

Gray whale, 3-14, 3-24, 3-27, 3-28, 3-30, 3-

31, 3-41, 9-4 

Guadalupe fur seal, 3-23 

Harbor porpoise, 3-17, 3-18, 3-21, 3-22, 3-23, 

3-27, 3-28, 3-30, 9-4 

Harbor seal, 3-17, 3-18, 3-20, 3-23, 3-24, 3-

25, 3-26, 3-30, 3-41, 6-5, 9-4 

Harp seal, 3-17, 3-20 

Hawaiian monk seal, 3-7, 3-33, 3-34, 9-4 

Hooded seal, 3-17, 3-20 

Humpback whale, 1-2, 3-17, 3-18, 3-19, 3-20, 

3-21, 3-22, 3-24, 3-26, 3-27, 3-29, 3-30, 3-

33, 4-34, 8-2, 8-8, 9-4 

Ice seal, 3-17, 3-18, 3-41 

Ice seals, 3-17, 3-18, 3-41 

Killer whale, 3-7, 3-17, 3-26, 3-27, 3-29, 3-30, 

3-33, 9-1 

Marine Mammal Health and Stranding 

Response Program (MMHSRP), 1-1, 1-2, 

 1-3, 1-4, 1-6, 1-7, 1-8, 1-9, 1-10, 1-11, 1-12, 

1-13, 1-14, 1-15, 2-1, 2-2, 2-6, 2-13, 2-14, 

2-16, 3-1, 3-2, 3-5, 3-18, 3-46, 3-48, 4-42, 

4-45, 5-2, 5-3, 5-5, 5-7, 5-8, 5-19, 5-23, 6-1, 

6-2, 6-3, 6-4, 6-5, 6-6 

Marine Mammal Protection Act (MMPA), 

 1-1, 1-2, 1-3, 1-4, 1-6, 1-8, 1-9, 1-10, 1-11, 

1-12, 1-15, 2-1, 2-3, 2-6, 2-11, 2-12, 2-13, 

2-14, 2-15, 2-16, 2-17, 3-3, 3-4, 3-5, 3-17, 

3-20, 3-23, 3-26, 3-29, 3-33, 3-41, 4-3, 4-

11, 4-52, 4-58, 4-61, 5-2, 5-3, 5-5, 5-7, 5-8, 

5-9, 5-10, 5-14, 6-1, 6-3, 6-4, 9-1, 9-3, 9-5 

Mass stranding, 1-4, 2-2, 3-14, 3-17, 3-18, 3-

21, 3-27, 3-30, 4-6, 4-9 

Melon-headed whale, 3-21, 3-33 

Minke whale, 3-17, 3-18, 3-21, 3-24, 3-30, 9-4 

National Environmental Policy Act (NEPA), 

1-1, 1-9, 1-13, 1-15, 2-5, 3-1, 3-40, 6-6 

National Estuarine Research Reserve (NERR), 

3-6, 3-7, 4-61, 5-1 

National Historic Preservation Act (NHPA), 

3-40 

National Marine Fisheries Service (NMFS), 

 1-1, 1-2, 1-3, 1-4, 1-5, 1-6, 1-8, 1-9, 1-10, 1-

11, 1-13, 1-14, 1-15, 2-1, 2-2, 2-3, 2-4, 2-6, 

2-7, 2-8, 2-9, 2-10, 2-11, 2-12, 2-13, 2-14, 
Marine Mammal Health and Stranding Response Program 

Final Programmatic Environmental Impact Statement February 2009 

10-2 

2-15, 2-16, 2-17, 3-2, 3-3, 3-4, 3-5, 3-6, 3-

10, 3-11, 3-13, 3-14, 3-17, 3-18, 3-20, 3-21, 

3-23, 3-26, 3-29, 3-32, 3-41, 4-3, 4-9, 4-10, 

4-11, 4-20, 4-24, 4-34, 4-38, 4-52, 4-61, 4-

63, 5-2, 5-3, 5-4, 5-5, 5-6, 5-7, 5-8, 5-9, 5-

10, 5-11, 5-14, 5-15, 5-18, 5-19, 5-20, 5-23, 

6-2, 8-4, 8-5, 8-6, 8-8, 9-1 

National Marine Sanctuary, 3-2, 3-6, 3-7, 3-8, 

5-1, 5-10, 8-6, 8-7 

National Register of Historic Places (NRHP), 

3-40, 3-42, 8-6, 8-7 

National Wildlife Refuge (NWR), 3-2, 3-6, 3-

7, 3-12 

North Atlantic right whale, 3-6, 3-17, 3-20, 3-

21, 3-22, 4-24, 4-25, 8-1, 8-4, 8-5 

North Pacific right whale, 3-7, 3-23, 3-26, 3-

29 

Northern fur seal, 3-26, 3-41, 9-4 

Pacific white-sided dolphin, 3-24, 3-27, 3-30 

Pantropical spotted dolphin, 3-21 

Permit, 1-8, 1-9, 1-10, 1-11, 1-12, 1-15, 2-1, 

2-2, 2-11, 2-12, 2-13, 2-14, 3-4, 3-5, 4-3, 5-

2, 5-3, 5-5, 5-7, 5-8, 5-9, 5-10, 5-11, 5-14, 

5-15, 6-4 

pinniped, 2-9, 3-17, 3-19, 3-20, 3-23, 3-27, 3-

28, 3-30, 3-33, 3-44, 4-7, 4-24, 4-25, 4-26, 

4-30, 4-34, 4-57, 4-63, 5-8 

Pygmy sperm whale, 3-17, 3-21 

Ribbon seals, 3-41 

Ringed seals, 3-41 

Rough-toothed dolphin, 1-6, 3-21, 3-24 

Sea otter, 1-1, 3-4, 3-23, 3-29, 3-31, 3-41 

Sei whale, 3-17, 3-20, 3-21, 3-23, 3-26, 3-29 

Sperm whale, 3-17, 3-20, 3-21, 3-23, 3-24, 3-

26, 3-27, 3-29, 3-30, 3-33, 8-8, 9-4 

Spotted seals, 3-41 

Standards for Marine Mammal Rehabilitation 

Facilities, 1-9, 2-7, 2-8, 4-2, 4-16, 4-17, 4-

18, 4-55, 4-63, 4-68, 5-4, 5-5, 5-20, 5-23, 6-

5 

Standards for the Release of Rehabilitated 

Marine Mammals, 1-9, 2-10, 4-2, 4-22, 4-

23, 4-64, 4-69, 5-6, 6-2, 6-3, 6-5 

Steller sea lion, 3-7, 3-23, 3-26, 3-29, 3-30, 3-

41, 4-29, 8-1, 9-4 

Stranding Agreement (SA), 1-4, 1-8, 1-9, 1-

11, 1-12, 2-1, 2-2, 2-3, 2-4, 2-6, 2-8, 2-10, 

2-11, 3-49, 4-2, 4-3, 4-9, 4-10, 4-11, 4-17, 

4-39, 4-46, 4-50, 4-51, 4-58, 4-59, 4-60, 4-

63, 4-64, 4-66, 4-67, 5-1, 5-2, 5-3, 5-4, 5-5, 

5-6, 5-8, 5-15, 5-16, 5-17, 5-18, 5-19, 5-20, 

5-21, 5-22, 6-3 

Stranding Agreement National Template, 5-19 

Threatened species, 1-9, 1-10, 2-2, 2-4, 2-8, 2-

15, 3-1, 3-2, 3-3, 3-4, 3-5, 3-6, 3-7, 3-10, 3-

11, 3-12, 3-17, 3-20, 3-23, 3-26, 3-29, 3-32, 

3-37, 3-39, 4-2, 4-3, 4-11, 4-15, 4-16, 4-19, 

4-24, 4-26, 4-27, 4-60, 4-67, 4-68, 5-3, 5-9, 

6-2, 6-5, 9-1, 9-2 

Unusual Mortality Event (UME), 1-3, 1-4, 1-

6, 1-11, 2-17, 3-14, 3-18, 3-22, 3-24, 3-28, 

3-31, 3-34, 4-27, 4-28, 5-6, 9-5 

West Indian manatee, 3-6, 3-7, 3-8, 3-20, 3-22 

 
Photo by Lynne Barre, 

Photo by PCCS 

Photo by NMFS NWR 

Final Programmatic Environmental Impact Statement 

for the Marine Mammal Health and 

Stranding Response Program 

February 2009 

Volume II: Appendices A-F 

Photo by ASLC 

Photo by Ingrid Overgard 

National Marine Fisheries Service 

Office of Protected Resources 

1315 East-West Highway 

Silver Spring, MD 20910 

A-1

Federal Agencies 

U.S. Environmental Protection Agency 

U.S. Environmental Protection Agency 

Office of Federal Activities 

EIS Filing Section 

Ariel Rios Building (South Oval Lobby) 

Mail Code 2252-A 

1200 Pennsylvania Avenue NW 

Washington, D.C. 20460

Ms. Betsy Higgins 

Environmental Review Coordinator 

U.S. Environmental Protection Agency, 

Region 1 

One Congress Street, 11th Floor 

Boston, MA 02203-0001

Ms. Grace Musumeci 

Environmental Review Coordinator 

U.S. Environmental Protection Agency, 

Region 2 

290 Broadway, 25th Floor 

New York City, NY 10007 

Mr. Bill Arguto 

Environmental Review Coordinator 

U.S. Environmental Protection Agency, 

Region 3 

1650 Arch Street 

Philadelphia, PA 19106 

Mr. Heinz Mueller 

Environmental Review Coordinator 

U.S. Environmental Protection Agency, 

Region 4 

61 Forsyth Street 

Atlanta, GA 30303 

Ms. Cathy Gilmore 

Environmental Review Coordinator 

U.S. Environmental Protection Agency, 

Region 6 

1445 Ross Avenue, 12th Floor, Suite 1200 

Dallas, TX 75202-2733 

Nova Blazej 

Environmental Review Coordinator 

U.S. Environmental Protection Agency, 

Region 9 

75 Hawthorne Street 

San Francisco, CA 94105 

Ms. Christine Reichgott 

Environmental Review Coordinator 

U.S. Environmental Protection Agency, 

Region 10 

1200 Sixth Avenue 

Seattle, WA 98101 

U.S. Department of Commerce 

Ms. Mary Colligan 

Assistant Regional Administrator, 

Protected Resources 

National Marine Fisheries Service 

55 Great Republic Drive 

Gloucester, MA 01930 

Ms. Donna Darm 

Assistant Regional Administrator, 

Protected Resources 

National Marine Fisheries Service 

7600 Sand Point Way NE 

Seattle, WA 98115-0070 

Mr. David Bernhart 

Assistant Regional Administrator, 

Protected Resources 

National Marine Fisheries Service 

263 13th Avenue, South 

St. Petersburg, FL 33701 

Mr. Russ Strach 

Assistant Regional Administrator, 

Protected Resources 

National Marine Fisheries Service 

501 West Ocean Boulevard, Suite 4200 

Long Beach, CA 90802-4213 

Ms. Kaja Brix 

Assistant Regional Administrator, 

Protected Resources 

National Marine Fisheries Service 

P.O. Box 21668 

Juneau, AK 99802-1668 

Ms. Lisa Van Attta 

Assistant Regional Administrator, 

Protected Resources 

National Marine Fisheries Service 

1601 Kapiolani Boulevard, Suite 1110 

Honolulu, HI 96814 

Ms. Patricia Kurkul 

Regional Administrator 

Northeast Region 

National Marine Fisheries Service 

55 Great Republic Drive 

Gloucester, MA 01930 

Mr. Barry Thom 

Acting Regional Administrator 

Northwest Region 

National Marine Fisheries Service 

7600 Sand Point Way NE 

Bin C 15700, Building 1 

Seattle, WA 98115 
A-2

Dr. Roy E. Crabtree 

Regional Administrator 

Southeast Region 

National Marine Fisheries Service 

263 13th Avenue, South 

St. Petersburg, FL 33701 

Mr. Rodney R. McInnis 

Regional Administrator 

Southwest Region 

National Marine Fisheries Service 

501 West Ocean Boulevard, Suite 4200 

Long Beach, CA 90802-4213 

Mr. Doug Mecum 

Acting Regional Administrator 

Alaska Region 

National Marine Fisheries Service 

P.O. Box 21668 

Juneau, AK 99802-1668 

Mr. William L. Robinson 

Regional Administrator 

Pacific Islands Region 

National Marine Fisheries Service 

1601 Kapiolani Boulevard, Suite 1110 

Honolulu, HI 96814 

Dr. Nancy Thompson 

Director 

Northeast Fisheries Science Center 

National Marine Fisheries Service 

166 Water Street 

Woods Hole, MA 02543-1026 

Dr. Usha Varanasi 

Director 

Northwest Fisheries Science Center 

National Marine Fisheries Service 

2725 Montlake Boulevard East 

Seattle, WA 98112 

Dr. Bonnie Ponwith 

Director 

Southeast Fisheries Science Center 

National Marine Fisheries Service 

75 Virginia Beach Drive 

Miami, FL 33149 

Dr. Norm Bartoo 

Director 

Southwest Fisheries Science Center 

National Marine Fisheries Service 

8604 LaJolla Shores Drive 

LaJolla, CA 92037-1508 

Dr. Samuel Pooley 

Director 

Pacific Islands Fisheries Science Center 

National Marine Fisheries Service 

2750 Dole Street 

Honolulu, HI 96822 

Dr. Douglas DeMaster 

Director 

Alaska Fisheries Science Center, National Marine 

Mammal Laboratory 

National Marine Fisheries Service 

7600 Sand Point Way NE 

Seattle, WA 98115-6349 

Ms. Mendy Garron 

Northeast Regional Stranding Coordinator 

National Marine Fisheries Service 

55 Great Republic Drive 

Gloucester, MA 01930 

Mr. Brent Norberg 

Northwest Regional Stranding Coordinator 

National Marine Fisheries Service 

7600 Sand Point Way NE 

Seattle, WA 98115 

Ms. Blair Mase-Guthrie 

Southeast Regional Stranding Coordinator 

National Marine Fisheries Service 

75 Virginia Beach Drive 

Miami, FL 33149 

Mr. Joseph Cordaro 

Southwest Regional Stranding Coordinator 

National Marine Fisheries Service 

501 West Ocean Boulevard, Suite 4200 

Long Beach, CA 90802-4213 

Ms. Aleria Jensen 

Alaska Regional Stranding Coordinator 

National Marine Fisheries Service 

P.O. Box 21668 

Juneau, AK 99802-1668 

Mr. David Schofield 

Pacific Islands Regional Stranding Coordinator 

National Marine Fisheries Service 

1601 Kapiolani Boulevard, Suite 1110 

Honolulu, HI 96814 

Mr. Jamison Smith 

East Coast Disentanglement Coordinator 

National Marine Fisheries Service 

55 Great Republic Drive 

Gloucester, MA 01930 

Ms. Laura Engleby 

Marine Mammal Branch Chief, Southeast Region 

National Marine Fisheries Service 

263 13th Avenue, South 

St. Petersburg, FL 33701 

 
A-3

Ms. Lanni Hall 

Northeast Region 

National Marine Fisheries Service 

55 Great Republic Drive 

Gloucester, MA 01930 

Ms. Lynne Barre 

Northwest Region 

National Marine Fisheries Service 

7600 Sand Point Way NE 

Seattle, WA 98115 

Ms. Kristin Wilkinson 

Northwest Region 

National Marine Fisheries Service 

7600 Sand Point Way NE 

Seattle, WA 98115 

Dr. Erin Fougeres 

Stranding Program Administrator 

Southeast Region 

National Marine Fisheries Service 

263 13th Avenue, South 

St. Petersburg, FL 33701 

Ms. Barb Mahoney 

Alaska Region 

National Marine Fisheries Service 

P.O. Box 43 

Anchorage, AK 99513-7577 

Ms. Sarah Wilkin 

Southwest Regional Office 

National Marine Fisheries Service 

501 West Ocean Boulevard, Suite 4200 

Long Beach, CA 90802-4213 

Dr. George A. Antonelis, Jr. 

Pacific Islands Fisheries Science Center 

National Marine Fisheries Service 

2570 Dole Street 

Honolulu, HI 96822-2396 

Dr. Paul R. Becker 

Hollings Marine Laboratory 

National Institute of Standards and Technology 

331 Fort Johnson Road 

Charleston, SC 29412 

Mr. Timothy Cole 

Northeast Fisheries Science Center 

National Marine Fisheries Service 

166 Water Street 

Woods Hole, MA 02543-1027 

Dr. Tracy K. Collier 

Environmental Conservation Division 

Northwest Fisheries Science Center 

National Marine Fisheries Service 

2725 Montlake Boulevard East 

Seattle, WA 98112 

Dr. Ruth Ewing 

Southeast Fisheries Science Center 

National Marine Fisheries Service 

75 Virginia Beach Drive 

Miami, FL 33149-1004 

Mr. Larry Hansen 

Southeast Fisheries Science Center 

National Marine Fisheries Service 

101 Pivers Island Road 

Beaufort, NC 28517 

Dr. Lori Schwacke 

USDOC/NOAA/NOS/NCCOS 

CCEHBR at Charleston 

331 Fort Johnson Road 

Charleston, SC 29412 

Mr. Edward Lyman 

Hawaiian Islands Humpback Whale National 

Marine Sanctuary 

NOAA/National Ocean Service 

726 South Kihei Road 

Kihei, HI 96753 

Dr. David Mattila 

Hawaiian Islands Humpback Whale National 

Marine Sanctuary 

NOAA/National Ocean Service 

726 South Kihei Road 

Kihei, HI 96753 

Ms. Rebecca Pugh 

Hollings Marine Laboratory 

National Institute of Standards and Technology 

331 Fort Johnson Road 

Charleston, SC 29412 

Dr. David Rotstein 

NOAA Center for Marine Animal Health 

Department of Pathobiology 

College of Veterinary Medicine 

University of Tennessee 

2407 River Drive, Room A201 

Knoxville, TN 37996-4542 

Dr. John E. Stein 

Northwest Fisheries Science Center 

National Marine Fisheries Service 

2725 Montlake Boulevard East 

Seattle, WA 98112 

 
A-4

Ms. Angela Somma 

Chief, Endangered Species Division 

Office of Protected Resources 

National Marine Fisheries Service 

1315 East-West Highway 

Silver Spring, MD 20910 

Ms. Amy Sloan 

Permits, Conservation and Education Division 

Office of Protected Resources 

National Marine Fisheries Service 

1315 East-West Highway 

Silver Spring, MD 20910 

Ms. Tamra Faris 

National Marine Fisheries Service 

1201 North-East Lloyd Boulevard 

Portland, OR 97232 

Mr. Daniel Basta 

Director 

NOAA’s National Marine Sanctuaries 

1305 East-West Highway, Rm. 11523 

Silver Spring, MD 20910 

U.S. Department of the Interior 

Ms. Pat Carter 

NEPA Coordinator 

U.S. Fish and Wildlife Service 

4401 North Fairfax Drive 

Arlington, VA 22203 

Ms. Marjorie Nelson 

Chief, Branch of Consultation and HCPs 

Endangered Species Program 

U.S. Fish and Wildlife Service 

4401 North Fairfax Drive 

Arlington, VA 22203 

Dr. John Fay 

Branch of Consultation and HCPs 

Endangered Species Program 

U.S. Fish and Wildlife Service 

4401 North Fairfax Drive 

Arlington, VA 22203 

Dr. Kenneth J. Havran 

Office of Environmental Policy and Compliance

U.S. Department of the Interior (MS 2342)

1849 C Street, NW, 

Washington, DC 20240 

Dr. Willie R. Taylor 

Director

Office of Environmental Policy and Compliance

U.S. Department of the Interior (MS 2342)

1849 C Street, NW, 

Washington, DC 20240 

Ms. Diane Bowen 

U.S. Fish and Wildlife Service 

4401 North Fairfax Drive 

Arlington, VA 22203 

U.S. Department of Agriculture 

Dr. Barbara Kohn 

U.S. Department of Agriculture 

Animal and Plant Health Inspection Service 

4700 River Road, Unit 84 

Riverdale, MD 20737 

Dr. Laurie Gage 

U.S. Department of Agriculture 

Animal and Plant Health Inspection Service 

1131 Second Avenue 

Napa, CA 94558 

U.S. Department of Homeland Security 

Vice Admiral D. Brian Peterman 

Commander, Atlantic Area 

U.S. Coast Guard 

431 Crawford Street 

Portsmouth, VA 23704-5004 

Vice Admiral Charles D. Wurster 

Commander, Pacific Area 

U.S. Coast Guard 

Coast Guard Island, Bldg. 51-5 

Alameda, CA 94501 

Marine Mammal Commission 

Mr. David Laist 

Marine Mammal Commission 

4340 East-West Highway, Suite 905 

Bethesda, MD 20814 

Dr. Timothy J. Ragen 

Executive Director 

Marine Mammal Commission 

4340 East-West Highway, Suite 905 

Bethesda, MD 20814 
A-5

State Coastal Zone Management- Federal Consistency Contacts 

Mr. Scott Brown 

Program Chief 

Coastal Programs Office 

Department of Environmental Management 

4171 Commanders Drive 

Mobile, AL 36615 

Mr. Randy Bates 

Program Manager 

Alaska Coastal Management Program 

Office of Project Management & Permitting 

Department of Natural Resources 

302 Gold Street, Suite 202 

Juneau, AK 99811-0030 

Ms. Gene Brighouse-Failauga 

Program Manager 

Department of Commerce 

Government of American Samoa 

Pago Pago, AS 96799 

Mr. Mark Delaplaine 

Federal Consistency Manager 

California Coastal Commission 

45 Fremont Street, Suite 2000 

San Francisco, CA 94105-2219 

Mr. Tim Eichenberg 

San Francisco Bay Conservation & 

Development Commission 

50 California Street, Suite 2600 

San Francisco, CA 94111-4704 

Mr. Tom Ouellette 

Office of Long Island Sound Programs 

Department of Environmental Protection 

79 Elm Street, 3rd Floor 

Hartford, CT 06106-5127 

Ms. Susan Love 

Delaware Coastal Programs 

Department of Natural Resources & 

Environmental Control 

89 Kings Highway 

Dover, DE 19901 

Mr. Danny Clayton 

Florida Coastal Management Program 

Department of Environmental Protection 

3900 Commonwealth Boulevard 

Douglas Building, Mail Station 47 

Tallahassee, FL 32399-3000 

Ms. Kelie Moore 

Coastal Zone Management Program 

Department of Natural Resources 

One Conservation Way, Suite 300 

Brunswick, GA 31520-8687 

Ms. Amelia DeLeon 

Bureau of Planning 

Government of Guam 

P.O. Box 2950 

Agana, GU 96910 

Mr. John Nakagawa 

Hawaii Coastal Zone Management Program 

Department of Business, Economic 

Development, & Tourism 

P.O. Box 2359 

Honolulu, HI 96804 

Mr. Gregory J. DuCote 

Department of Natural Resources 

P.O. Box 44487 

617 North 3rd Street, Suite 1048 

Baton Rouge, LA 70808-4487 

Mr. Todd Burrowes 

State Planning Office 

State House Station #38 

184 State Street 

Augusta, ME 04333 

Mr. Elder Ghigiarelli, Jr. 

Wetlands and Waterways Program 

Maryland Department of the Environment 

Montgomery Park Business Center 

1800 Washington Boulevard, Suite 430 

Baltimore, MD 21230-1708 

Mr. Robert Boeri 

Acting Project Review Coordinator 

Office of Coastal Zone Management 

Executive Office of Environmental Affairs 

251 Causeway Street, Suite 900 

Boston, MA 02114 

Mr. Mike Walker 

Mississippi Coastal Program 

Department of Marine Resources 

1141 Bayview Avenue, Suite 101 

Biloxi, MS 39530 

Mr. Chris Williams 

New Hampshire Coastal Program 

Department of Environmental Services 

50 International Drive, Suite 200 

Pease International Tradeport 

Portsmouth, NH 03801 

Ms. Kim Springer 

Land Use Regulation Program 

Department of Environmental Protection 

P.O. Box 439 

Trenton, NJ 08625 

 
A-6

Mr. Steven C. Resler 

Deputy Bureau Chief 

Division of Coastal Resources & Waterfront 

Revitalization 

Department of State 

41 State Street 

Albany, NY 12231-0001 

Mr. Steve Rynas 

Division of Coastal Management 

Department of Environment & Natural Resources 

400 Commerce Avenue 

Morehead City, NC 28557-3421 

Ms. Anne Agulto 

Commonwealth of the Northern Mariana 

Islands 

Coastal Resources Management Office 

Morgen Building, 2nd Floor 

San Jose, Saipan, MP 96950 

Mr. Dale Banton 

Federal Program Officer 

Ocean and Coastal Program 

Department of Land Conservation & Development 

635 Capitol Street, NE, Room 150 

Salem, OR 97301 

Mr. Larry Toth 

Water Planning Office 

Department of Environmental Protection 

400 Market Street, 15th Floor 

P.O. Box 2063 

Harrisburg, PA 17105-2063 

Ms. Rose A. Ortiz 

Planning Analyst 

Puerto Rico Planning Board 

P.O. Box 41119 

San Juan, PR 00940-1119 

Mr. Jeff Willis 

Coastal Resources Management Council 

Stedman Office Building 

4808 Tower Hill Road 

Wakefield, RI 02879-1900 

Ms. Barbara Neale 

Director 

Regulatory Programs Division 

Office of Ocean & Coastal Resource Management 

Department of Health & Environmental Control 

1362 McMillian Avenue, Suite 400 

Charleston, SC 29405-2029 

Ms. Tammy Brooks 

Coastal Division, Texas General Land Office 

Stephen F. Austin Building 

1700 North Congress Street 

Austin, TX 78701 

Mr. Charles H. Ellis III 

EIR/Consistency Coordinator 

Office of Environmental Impact Review 

629 East Main Street 

Richmond, VA 23219 

Mr. Jean-Pierre Oriol 

Division of Coastal Zone Management 

Department of Planning and Natural Resources 

C.E.K. Airport, Terminal Building, 2nd Floor 

St. Thomas, VI 00802 

Ms. Loree Randall 

Shorelands & Environmental Assistance Program 

Department of Ecology 

P.O. Box 47600 

Olympia, WA 98504-7600 

State/Territory Historic Preservation Offices 

Dr. David A Poirier 

Connecticut State Historic Preservation Office 

59 South Prospect Street 

Hartford, CT 06106 

Mr. Frederick Gaske 

State Historic Preservation Officer 

Florida Division of Historical Resources 

Department of State 

500 S. Bronough Street, Room 305 

Tallahassee, FL 32399-0250 

Mr. Jay Schleier 

Oregon State Parks & Recreation Department 

725 Summer Street, NE, Suite C 

Salem, OR 97301-1271 

Ms. Aida Belen Rivera Ruiz 

Historic Preservation Officer 

Puerto Rico Office of Historic Preservation 

P.O. Box 9066581 

San Juan, PR 00906-6581 

State/Territory Environmental Resource Departments 

Mr. Tom McCloy 

New Jersey Department of Environmental 

Protection and Energy 

Division of Fish and Wildlife 

P.O. Box 400 

Trenton, NJ 08625 

New York Department of Environmental 

Conservation 

Division of Fish, Wildlife, and Marine Resources 

625 Broadway 

Albany, NY 12233 
A-7

Mr. Michael Lapisky 

Rhode Island Department of Environmental 

Management 

Division of Fish and Wildlife 

4808 Tower Hill Road 

Wakefield, RI 02879 

Mr. William Rohring 

Assistant Director of CZM 

C.E.K. Airport Terminal Building, 2nd Floor 

St. Thomas, VI 00802 

National Marine Mammal Stranding Network 

Dr. Sean Todd 

Allied Whale, College of the Atlantic 

105 Eden Street 

Bar Harbor, ME 04609 

Ms. Lynda Doughty 

Maine Department of Marine Resources 

P.O. Box 8 

Boothbay Harbor, ME 04575 

Mr. Keith A. Matassa 

University of New England 

11 Hills Beach Road 

Biddeford, ME 04005 

Mr. Claudio Corbelli 

The Whale Center of New England 

24 Harbor Loop 

Gloucester, MA 01930 

Ms. Connie Merigo 

New England Aquarium 

Central Wharf 

Boston, MA 02110 

Ms. Katie Touhey 

IFAW/Cape Cod Stranding Network 

290 Summer Street 

Yarmouth Port, MA 02675 

Ms. Heather Medic 

Mystic Aquarium 

55 Coogan Boulevard 

Mystic, CT 06355-1997 

Ms. Kim Durham 

New York Riverhead Foundation 

for Marine Research 

467 East Main Street 

Riverhead, NY 11901 

Mr. Robert Schoelkopf 

Marine Mammal Stranding Center 

P.O. Box 773 

Brigantine, NJ 08203 

Ms. Suzanne Thurman 

MERR Institute, Inc. 

P.O. Box 411 

Nassau, DE 19969 

Ms. Cindy Driscoll 

Maryland Department of Natural Resources 

Cooperative Oxford Laboratory 

904 South Morris Street 

Oxford, MD 21654 

Mr. Brent Whittaker 

National Aquarium in Baltimore 

501 East Pratt Street, Pier 3 

Baltimore, MD 21202-3194 

Mr. Charley Potter 

Smithsonian Institution 

National Museum of Natural History 

Washington, D.C. 20560 

Ms. Susan G. Barco 

Virginia Aquarium & Marine Science Center 

717 General Booth Boulevard 

Virginia Beach, VA 23451 

Ms. Kathryn Zagzebski 

National Marine Life Center 

P.O. Box 269 

Buzzards Bay, MA 02532 

Dr. Jack Musick 

Virginia Institute of Marine Science 

College of William and Mary 

P.O. Box 1346 

Gloucester Point, VA 23062 

Ms. Gretchen Lovewell 

National Marine Fisheries Service 

Southeast Fisheries Science Center 

Beaufort Laboratory 

101 Pivers Island Road 

Beaufort, NC 28516 

Duke University Marine Laboratory 

Nicholas School of the Environment & Earth 

Sciences 

135 Duke Marine Lab Road 

Beaufort, NC 28516-9721 

Mr. William McLellan 

UNCW Marine Mammal Stranding Program 

Biological Sciences, UNCW 

601 South College Road 

Wilmington, NC 28403 

Dr. Craig Harms 

North Carolina State University 

College of Veterinary Medicine 

Center for Marine Sciences and Technology 

303 College Circle 

Morehead City, NC 28557 

 
A-8

Dr. Robert Young 

Department of Marine Science 

Coastal Carolina University 

P.O. Box 261954 

Conway, SC 29528-6054 

Mr. Wayne McFee 

USDOC/NOAA/NOS/NCCOS 

CCEHBR at Charleston 

219 Fort Johnson Rd 

Charleston, SC 29412-9110 

South Carolina Department of Natural 

Resources 

Marine Resources Division 

P.O. Box 12559 

Charleston, SC 29422 

Georgia Marine Mammal Stranding Network 

Georgia Department of Natural Resources 

One Conservation Way 

Brunswick, GA 31520 

FWC Apalachicola National Reserve 

350 Carroll Street 

Eastpoint, FL 32399 

Dynamac Corporation 

DYN-2 

Kennedy Space Center, FL 32899 

Clearwater Marine Aquarium 

249 Windward Passage 

Clearwater, FL 33767 

Gulf World Marine Park 

15412 Front Beach Road 

Panama City, FL 32413 

Gulf Islands National Seashore 

1801 Gulf Breeze Parkway 

Gulf Breeze, FL 32563 

Ms. Amanda Wilkerson 

Emerald Coast Wildlife Refuge Inc. 

 406 Mountain Drive 

Destin, FL 32541 

Ms. Pamela Sweeney 

Marine Animal Rescue Society 

P.O. Box 833356 

Miami, FL 33283 

Mr. Steve McCulloch 

Harbor Branch Oceanographic Institute, Inc. 

5600 US 1 North 

Fort Pierce, FL 34946 

Marine Mammal Stranding Network-Southwest 

Region 

1210 SE 21st Street 

Cape Coral, FL 33990 

Mr. Robert Lingenfelser 

Marine Mammal Conservancy 

P.O. Box 1625 

102200 Overseas Highway 

Key Largo, FL 33037-1625 

Mote Marine Laboratory 

1600 Ken Thompson Parkway 

Sarasota, FL 34236-1096 

Florida Fish and Wildlife Conservation 

Commission, Fish and Wildlife Research Institute 

Marine Mammal Pathobiology Laboratory 

3700 54th Avenue S 

St. Petersburg, FL 33711 

The Florida Aquarium 

701 Channelside Drive 

Tampa, FL 33602 

Mr. Bill Hughes 

SeaWorld Orlando 

7007 SeaWorld Drive 

Orlando, FL 32821 

Florida Fish and Wildlife Conservation 

Northeast Field Laboratory 

6164 Authority Avenue 

Jacksonville, FL 32221 

Ms. Delphine Vanderpool 

Institute for Marine Mammal Studies 

P.O. Box 207 

Gulfport, MS 39502 

Marterra Foundation, Inc. 

P.O.Box 646 

Gulf Shores, AL 36547 

Hubbs-Sea World Research institute 

6295 Sea Harbor Drive 

Orlando, FL 32821 

Ms. Grisel Rodriguez-Ferrer 

Puerto Rico Department of Natural and 

Environmental Resources 

P.O. Box 9066600 

San Juan, PR 00906-6600 

Dr. Luis E. Figueroa 

Mayaguez Zoo 

Puerto Rico National Park Company 

108 Street Bo Miradero 

Mayaguez, PR 00661 

National Marine Fisheries Service 

Southeast Fisheries Science Center 

Pascagoula Laboratory 

3209 Frederic Street 

Pascagoula, MS 39567 

Mississippi Department of Marine Resources 

1141 Bayview Avenue, Suite 101 

Biloxi, MS 39530 
A-9

John Hewitt 

Audubon Aquarium of the Americas 

#1 Canal Street 

New Orleans, LA 70130 

National Marine Fisheries Service 

Southeast Fisheries Science Center 

Galveston Laboratory 

4700 Avenue U 

Galveston, TX 77551-5997 

Texas Marine Mammal Stranding Network 

4700 Avenue U, Building 303 

Galveston, TX 77551 

Texas State Aquarium 

2710 North Shoreline Boulevard 

Corpus Christi, TX 78402-1004 

Northcoast Marine Mammal Center 

424 Howe Drive 

Crescent City, CA 95531 

Ms. Michelle Berman 

Santa Barbara Museum of Natural History 

Vertebrate Laboratory 

2559 Puesta Del Sol Road 

Santa Barbara, CA 93105 

Ms. Jackie Jaakola 

Fort MacArthur Marine Mammal Care Center 

3601 South Gaffey Street 

San Pedro, CA 90731 

Ms. Shelbi Stoudt 

The Marine Mammal Center 

Marin Headlands 

1065 Fort Cronkhite 

Sausalito, CA 94965 

Ms. Michelle Hunter 

Pacific Marine Mammal Center 

20612 Laguna Canyon Road 

Laguna Beach, CA 92651 

Mr. Peter Howorth 

Santa Barbara Marine Mammal Center 

389 North Hope Avenue 

Santa Barbara, CA 93110 

Ms. Cynthia Reyes 

California Wildlife Center 

P.O. Box 2022 

Malibu, CA 90265 

Mr. Tom Goff 

SeaWorld San Diego 

Department of Animal Care 

500 Sea World Drive 

San Diego, CA 92109 

California Academy of Sciences 

Department of Ornithology & Mammalogy 

875 Howard Street 

San Francisco, CA 94103 

Marine Animal Rescue 

P.O. Box 821 

El Segundo, CA 90245 

Humboldt State University 

Vertebrate Museum 

1 Harpst Street 

Arcata, CA 95521 

Wildrescue 

20178 Rockport Way 

Malibu, CA 90265 

Moss Landing Marine Laboratories 

Vertebrate Ecology Laboratory 

P.O. Box 233 

Moss Landing, CA 95039 

Mr. Jim Dines 

Los Angeles County Museum of Natural History 

Section of Mammals 

900 Exposition Boulevard 

Los Angeles, CA 90007 

Long Beach Animal Control 

333 West Ocean Boulevard 

Long Beach, CA 90802 

Long Marine Laboratory 

Center for Ocean Health 

100 Shaffer Road 

Santa Cruz, CA 95060 

Ms. Susan Berta 

Orca Network 

2403 North Bluff 

Greenbank, WA 98253 

Ms. Serena Lockwood 

Wolf Hollow Wildlife Rehabilitation Center 

P.O. Box 391 

Friday Harbor, WA 98250 

Ms. Dyanna Lambourn 

Washington Department of Fish and Wildlife 

7810 Phillips Road, S.W. 

Tacoma, WA 98498 

Ms. Amy Traxler 

The Whale Museum 

P.O. Box 945 

Friday Harbor, WA 98250 

 
A-10

Mr. Jonathan Scordino 

Makah Tribe 

P.O. Box 115 

Neah Bay, WA 98357 

Dr. John Calambokidis 

Cascadia Research Collective 

218 1⁄2 West 4th Ave, 

Olympia, WA 98501 

Ms. Jennifer Convy 

PAWS Wildlife Rehabilitation Center 

P.O. Box 1037 

Lynwood, WA 98046 

Ms. Mary Sue Brancato 

Olympic Coast National Marine Sanctuary 

115 Railroad Ave, East, Suite 301 

Port Angeles, WA 98362 

Ms. Patti Happe 

Olympic Coast National Park 

600 East Park Avenue 

Port Angeles, WA 98362-6798 

Ms. Cinamon Moffett 

Port Townsend Marine Science Center 

Fort Worden State Park 

532 Battery Way 

Port Townsend, WA 98368 

Chrissy McLean 

East Jefferson County Marine Mammal 

Stranding Network 

532 Battery Way 

Port Townsend, WA 98320 

Ms. Mariann Brown 

Whatcom County Marine Mammal Stranding 

Network 

3883 Everett Lane 

Ferndale, WA 98248 

Ms. Deanna Lynch 

U.S. Fish and Wildlife Service 

510 Desmond Drive 

Lacey, WA 98503 

Wolftown Rehabilitation 

P.O. Box 13115 

Burton, WA 98013 

Mr. Al Rechtorman 

Seattle Animal Control 

2061 15th Avenue West 

Seattle, WA 98119 

Ms. Deb Dawson 

Edmonds Animal Control 

250 5th Ave N 

Edmonds, WA 98020 

Ms. Pam Sanguinetti 

Dungeness National Wildlife Refuge 

33 S. Barr Road 

Port Angeles, WA 98382 

Ms. Mary Jane Deuel 

Free Flight Wildlife Rehabilitation Center 

1185 Portland Avenue 

Bandon, OR 97411 

Ms. Deb Duffield 

Portland State University 

Department of Biology 

P.O. Box 751 

Portland, OR 97207 

Mr. Jim Rice 

Oregon State University 

2030 S. Marine Science Drive 

Newport, OR 97365 

Ms. Jan Hodder 

Oregon Institute of Marine Biology 

P.O. Box 5389 

Charleston, OR 97420 

Robin Brown 

Oregon Department of Fish and Wildlife 

Fish Division: Marine Resources Program 

7118 NE Vandenberg Avenue 

Corvallis, OR 97330-9446 

Ms. Judy Tuttle 

Oregon Coast Aquarium 

2820 SE Ferry Slip Road 

Newport, OR 97365 

Mr. Fred Sharpe 

Alaska Whale Foundation 

4739 University Way NE, #1239 

Seattle, WA 98105 

Mr. Tim Lebling 

Alaska SeaLife Center 

PO Box 1329 

Seward, AK 99664 

Ms. Kate Wynne 

Alaska Sea Grant Marine Advisory Program 

900 Trident Way 

Kodiak, AK 99615-7401 
A-11

Mr. Gary Frietag 

5786 Roosevelt Drive 

Ketchikan, AK 99835 

Dr. Kathy Burek 

Alaska Veterinary Pathology Services 

P.O. Box 773072 

Eagle River, AK 99577 

Ms. Sylvia Brunner and Mr. Gordon Jarrell 

University of Alaska Fairbanks 

Museum of the North 

907 Yukon Drive 

Fairbanks, AK 99775-1200 

Mr. Reid Brewer 

Unalaska Agent, Marine Advisory Program 

School of Fisheries and Ocean Sciences, UAF 

P.O. Box 526 

Unalaska, AK 99685 

Dr. Rachel Dziuba 

Bridge Veterinary Services 

10008 Crazy Horse Drive A-2 

Juneau, AK 99801 

Mr. Craig Matkin 

North Gulf Oceanic Society 

3430 Main St. B1 

Homer, AK 99603

Ms. Jan Straley 

University of Alaska Sitka 

P.O. Box 273 

Sitka, AK 99835 

Ms. Verena Gill 

U.S. Fish and Wildlife Service 

Marine Mammals Management 

1011 East Tudor Road, MS 341 

Anchorage, AK 99503 

Mr. Andy Aderman 

Togiak National Wildlife Refuge 

P.O. Box 270 

Dillingham, AK 99575 

Ms. Angela Doroff 

U.S. Fish and Wildlife Service 

Marine Mammals Management 

1011 East Tudor Road, MS 341 

Anchorage, AK 99503 

Jamie Womble 

National Park Service 

Glacier Bay National Park 

P.O. Box 140 

Gustavus, AK 99826 

Ms. Chris Gabriele and Ms. Janet Neilson 

National Park Service 

Glacier Bay National Park 

P.O. Box 140 

Gustavus, AK 99826 

Ms. Eileen Henniger 

Yakutat Tlingit Tribe 

P.O. Box 418 

Yakutat, AK 99689 

Ms. Lianna Jack and Ms. Donna Willoya 

Alaska Sea Otter and 

Steller Sea Lion Commission 

505 W. Northern Lights Boulevard, Suite 2 

Anchorage, AK 99503 

Ms. Lori Quakenbush 

Arctic Marine Mammals 

Alaska Department of Fish and Game 

1300 College Road 

Fairbanks, AK 99701 

Ms. Kimberlee B. Beckmen 

Division of Wildlife Conservation 

Alaska Department of Fish and Game 

1300 College Road 

Fairbanks, AK 99701-1599 

Mr. Phillip Zavadil and Ms. Aquilina Lestenkof 

Aleut Community of St. Paul 

P.O. Box 86 

St. Paul Island, AK 99660 

Dr. Jason Turner 

Department of Marine Science 

University of Hawaii at Hilo 

200 W. Kawili Street 

Hilo, HI 96720 

Jay T. Gutierrez 

Guam Department of Agriculture 

Division of Aquatic and Wildlife Resources 

163 Dairy Road 

Mangilao, GU 96913 

Dr. Kristi West 

Hawaii Pacific University 

45-045 Kamahameha Highway 

Kaneohe, HI 96744-5297 

Other Contacts 

Dr. Michael Moore 

Biology Department, MS #33 

Woods Hole Oceanographic Institution 

Woods Hole, MA 02543-1050 

Mr. John C. George 

North Slope Borough 

Department of Wildlife Management 

P.O. Box 69 

Barrow, AK 99724 

 
A-12

Dr. Heather Koopman 

Biological Sciences 

University of North Carolina, Wilmington 

601 S. College Road 

Wilmington, NC 28402 

Dr. Christina Lockyer 

North Atlantic Marine Mammal Commission 

Polar Environmental Center 

N-9296 Tromsø 

Norway 

Dr. Charles Mayo 

Provincetown Center for Coastal Studies 

59 Commercial Street 

Box 1036 

Provincetown, MA 02658 

Mr. Pieter Folkens 

Alaska Whale Foundation 

940 Adams Street, Suite F 

Benicia, CA 94510-2950 

Dr. James Mead 

Smithsonian Institution 

Division of Marine Mammals 

NHB 390, MRC 108 

P.O. Box 30712 

Washington, D.C. 20013-7013 

Dr. Randall Wells 

Chicago Zoological Society 

c/o Mote Marine Laboratory 

1600 Ken Thompson Parkway 

Sarasota, FL 34237 

Dr. Todd O’Hara 

Institute of Arctic Biology 

University of Alaska, Fairbanks 

P.O. Box 757000 

Fairbanks, AK 99775-7000 

Dr. Colleen Reichmuth Kastak 

Long Marine Laboratory 

University of California-Santa Cruz 

100 Shaffer Road 

Santa Cruz, CA 95060 

Dr. Jerome Barakos 

Pacific Campus of California Pacific Medical 

Center, 2nd Floor 

Department of Radiology 

Radiology Conference Center 

2333 Buchanan Street 

San Francisco, CA 94115 

Dr. Vicky Rowntree 

Department of Biology 

University of Utah 

257 South 1400 East 

Salt Lake City, UT 84113 

Dr. Robert Braun 

47-928 Kamokoi Road 

Kaneohe, HI 96744 

Dr. Gregg Levine 

National Marine Fisheries Service 

1601 Kapiolani Boulevard, Suite 1110 

Honolulu, HI 96814 

Dr. Beth Doescher and Mr. Jeff Pawloski 

Seal Life Park by Dolphin Discovery 

41-202 Kalanianaole Highway, Suite 7 

Waimanalo, HI 96795 

Dr. Richard DeJournett and Mr. Karl LaCour 

Koolau Radiology 

1380 Lusitana Street 

Honolulu, HI 96813 

Mr. Octavius Covington, Jr. 

Chief, Harbor Patrol 

Port of Long Beach 

925 Harbor Plaza Drive 

Long Beach, CA 90802 

Mr. Bart Bottoms 

532 Hot Springs Road 

Santa Barbara, CA 93108 

Environmental Management Division 

Harbor Department 

Port of Los Angeles 

P.O. Box 151 

San Pedro, CA 90733-0151 

Mr. Dean Tokishi 

Kaho'olawe Island Reserve Commission 

State of Hawaii 

811 Kolu StreetSuite 201 

Wailuku, HI 96793 

Mr. Todd Costa 

Department of Marine Safety 

City of Solana Beach 

P.O. Box 311 

Solana Beach, CA 92075 

Ms. Karen Pletnikoff 

Aleutian Pribilof Islands Association 

201 East Third Avenue 

Anchorage, AK 99501 

Vice President, Natural Resources 

Kawerak, Inc. 

P.O. Box 948 

Nome, AK 99762 

Ms. Hannah Bernard and Mr. Bill Gilmartin 

Hawaii Wildlife Fund 

P.O. Box 637 

Paia, Maui, HI 96779 
A-13

American Zoo and Aquarium Association 

8403 Colesville Road, Suite 710 

Silver Spring, MD 20910-3314 

American Cetacean Society 

P.O. Box 1391 

San Pedro, CA 90733-1391 

Earth Island Institute 

300 Broadway, Suite 28 

San Francisco, CA 94133 

Animal Welfare Institute 

P.O. Box 3650 

Washington DC 20027 

Friends of the Elephant Seal 

P.O. Box 490 

Cambria, CA 93428 

Cabrillo Marine Aquarium 

3720 Stephen White Drive 

San Pedro, CA 90731 

Mr. Alan Sanders 

Sierra Club 

232 North 3rd Street 

Port Hueneme, CA 93041 

Mr. Daniel Hayes Pearson 

Point Mugu Wildlife Center 

P.O. Box 1053 

Port Hueneme, CA 93044 

Dr. Paul Nachtigall and Ms. Marlee Breeze 

P.O. Box 1106 

Kailua, HI 96734 

Ms. Rebecca M.K. Hommon 

Region Counsel 

Navy Region Hawaii 

850 Ticonderoga Street, Room 303 

Pearl Harbor, HI 96860-5101 

Cha Smith 

KAHEA 

P.O. Box 27112 

Honolulu, HI 96827 

Ms. Kate Zolezzi 

General Manager 

Maui Ocean Center 

129 Ma'alaea Road 

Wailuku, HI 96793 

Ms. Regina Asmutis-Silvia 

Whale and Dolphin Conservation Society 

3 Jacqueline Lane 

Plymouth, MA 02360 

Ms. Marilee Menard 

Alliance of Marine Mammal Parks and 

Aquariums 

418 North Pitt Street 

Alexandria, VA 22314 

Public Libraries 

Boston Public Library 

Attn: Gale Fithian 

700 Boylston Street 

Boston, MA 02116 

Government Information Center 

San Francisco Public Library 

100 Larkin Street 

San Francisco, CA 94102 

Seattle Public Library 

Attn: Craig Kyte 

1000 4th Avenue 

Seattle, WA 98104 

St. Petersburg Public Library 

Attn: Joanne Balistreri 

3745 9th Avenue North 

St. Petersburg, FL 33713 

NOAA Central Library 

1315 East-West Highway 

SSMC3, Second Floor 

Silver Spring, MD 20910 
THIS PAGE INTENTIONALLY LEFT BLANK 
APPENDIX B 

AGENCY COORDINATION AND CONSULTATION 

UNITED STATES DEPARTMENT OF COMMERCE 

National Oceanic and Atmospheric Administration 

NATIONAL MARINE FISHERIES SERVICE 

Silver Spring. MO 209 1 0 

JUN 2 0 2006 

David A. Bergsten 

U.S. Department of Agriculture 

Animal and Plant Health Inspection Service 

4700 River Road, Unit 14 

Riverdale, MD 20737- 1238 

Dear Mr. Bergsten: 

The National Marine Fisheries Service (NMFS) is working on an Environmental Impact 

Statement (EIS) for the Marine Mammal Health and Stranding Response Program (MMHSRP). 

Some activities of the MMHSRP are conducted under a pennit issued under the MMPA and 

Section 10(a)(l)(A) of the Endangered Species Act (ESA) by the Permits, Conservation, and 

Education Division of the NMFS Office of Protected Resources. The current MMPAJESA 

permit expires on June 30,2007. A National Environmental Policy Act (NEPA) analysis of the 

activities covered under the permit must be completed prior to the issuance of a new permit. 

Potential future activities of the MMHSRP will also be analyzed in the EIS. 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The EIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

NMFS is the lead agency in the EIS process as defined in 40 CFR 1501.5. We invite your 

participation as a cooperating agency in this effort. Cooperating agency responsibilities are 

outlined in 40 CFR 1501.6. The degree of your involvement in the process will be determined by 

the extent of your authoritylresponsibilities; your interest, expertise, and resource availability; 

and your commitments. We encourage your full participation in the EIS process within the scope 

of your particular authority, responsibility, andlor expertise. This would include activities such 

as screening and evaluation of alternatives; information development; environmental, economic, 

or social analyses; and reviewing preliminary documents. However, at a minimum, we would 

request your assistance in developing information for the EIS within your expertise, as well as 

providing reviews of preliminary documents. 

@ Printed on Recycled P.pcr 
We look forward to your response, which should include a point of contact for your agency. If 

you have any questions, please contact Ms. Sarah Howlett or Ms. Sarah Wilkin at (301) 713- 

2322. 

Sincerely, 

Stewart Harris 

Acting Chief, 

Marine Mammal and Sea Turtle Division 

Office of Protected Resources 

National Marine Fisheries Service 
USDA, APHIS, AC 

United States 

DeoaKment of 

Agriculture 

Animal and 

Plant Health 

Inspection 

Service 

4700 River Road 

Unit 84 

Riverdale. MD 

20737 Mr. Stewarl Harris 

Acting ChieC, Marine Mammal and Sca Turtle Divisio~~ 

Office of Drotccted Resources 

NOAA. NMFS 

13 15 East West 1 Xighway 

Silvcr Spring, MU 20910 

Dear Mr. Harris: 

?'his is in regard to your letter of June 20, 2006, to David Bergsten, IJSDA, regarding 

cooperation on the EIS for the Marine Mammal Health and Sttanding Response Program 

'I'his leuct has been refered to mc, and I have been askcd to servc as the liaison and 

consulrant. 1 work for the Animal Care program, and am the Staff Veterinarian for 

E<xhibition Animals, including marine mammals. 1 work closely with your oflice. both 

with Drs. Whelan and Rowlcs. and with the Permits. Conservation, and Educatio~l 

Division. 

Please fecl free to contact me as necded during the EIS prqject. I have been involved in 

the development ofthc standards you reference. Thank you for you cooperation in this 

matter. 

If there any questions, please feel lice to contact this oftice. 

&+ atbara Ko n 

Anirnal Care 

301 -734-827 1 

301 -734-4978 (FAX) 

APHIS - Pmtccting ArndiitaO AgliCUltum 
THIS PAGE INTENTIONALLY LEFT BLANK 
UNlTED STATES DEPAmTMENT OF COMMERCE 

National Oceanic and Atmospheric Administration 

NATIONAL MARINE FISHERIES SERVICE 

Silver Spring. MO 209 1 0 

JIJN 2 0 2006 

Michael L. Gosliner, Esq. 

NEPA Coordinator 

Marine Mammal Commission 

4340 East-West Highway, Suite 905 

Bethesda, MD 208 14 

Dear Mr. Gosliner: 

The National Marine Fisheries Service (NMFS) is working on an Environmental Impact 

Statement (EIS) for the Marine Mammal Health and Stranding Response Program (MMHSRP). 

Some activities of the MMHSRP are conducted under a permit issued under the MMPA and 

Section lO(a)(l)(A) of the Endangered Species Act (ESA) by the Permits, Conservation, and 

Education Division of the NMFS Office of Protected Resources. The current MMPAIESA 

permit expires on June 30,2007. A National Environmental Policy Act (NEPA) analysis of the 

activities covered under the permit must be completed prior to the issuance of a new permit. 

Potential future activities of the MMHSRP will also be analyzed in the EIS. 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The EIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

NMFS is the lead agency in the EIS process as defined in 40 CFR 1501.5. We invite your 

participation as a cooperating agency in this effort. Cooperating agency responsibilities are 

outlined in 40 CFR 1501.6. The degree of your involvement in the process will be determined by 

the extent of your authority/responsibilities; your interest, expertise, and resource availability; 

and your commitments. We encourage your full participation in the EIS process within the scope 

of your particular authority, responsibility, andlor expertise. This would include activities such 

as screening and evaluation of alternatives; information development; environmental, economic, 

or social analyses; and reviewing preliminary documents. However, at a minimum, we would 

request your assistance in developing information for the EIS within your expertise, as well as 

providing reviews of preliminary documents. 

@ RYIUd on Recycled Paper 
We look forward to your response, which should include a point of contact for your agency. If 

you have any questions, please contact Ms. Sarah Howlett or Ms. Sarah Wilkin at (301) 713- 

2322. 

Sincerely, 

Stewart Harris 

Acting Chief, 

Marine Mammal and Sea Turtle Division 

Office of Protected Resources 

National Marine Fisheries Service 
Pat Carter 

NEPA Coordinator 

U.S. Fish and Wildlife Service 

4401 N. Fairfax Drive 

Arlington, VA 22203 

Dear Ms. Carter: 

UNITED STATES DEPARTMENT OF COMMERCE 

National Oceanic end Atmospheric Administration 

NATIONAL MARINE FISHERIES SERVICE 

Silver Spring. MD 209 1 0 

JUN 2 0 2006 

The National Marine Fisheries Service (NMFS) is working on an Environmental Impact 

Statement (EIS) for the Marine Mammal Health and Stranding Response Program (MMHSRP). 

Some activities of the MMHSRP are conducted under a permit issued under the MMPA and 

Section lO(a)(l)(A) of the Endangered Species Act (ESA) by the Permits, Conservation, and 

Education Division of the NMFS Office of Protected Resources. The current MMPAIESA 

permit expires on June 30,2007. A National Environmental Policy Act (NEPA) analysis of the 

activities covered under the permit must be completed prior to the issuance of a new permit. 

Potential future activities of the MMHSRP will also be analyzed in the EIS. 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The EIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

NMFS is the lead agency in the EIS process as defined in 40 CFR 1501 -5. We invite your 

participation as a cooperating agency in this effort. Cooperating agency responsibilities are 

outlined in 40 CFR 1501.6. The degree of your involvement in the process will be determined by 

the extent of your authority/responsibilities; your interest, expertise, and resource availability; 

and your commitments. We encourage your fir11 participation in the EIS process within the scope 

of your particular authority, responsibility, andlor expertise. This would include activities such 

as screening and evaluation of alternatives; information development; environmental, economic, 

or social analyses; and reviewing preliminary documents. However, at a minimum, we would 

request your assistance in developing information for the EIS within your expertise, as well as 

providing reviews of preliminary documents. 

@ Rinted on Recycled Paper 
We look forward to your response, which should include a point of contact for your agency. If 

you have any questions, please contact Ms. Sarah Howlett or Ms. Sarah Wilkin at (301) 713- 

2322. 

Sincerely, 

Stewart Harris 

Acting Chief, 

Marine Mammal and Sea Turtle Division 

Office of Protected Resources 

National Marine Fisheries Service 
United States Department of the Interior 

FISH AND WILDLIFE SERVICE 

Washington, D.C. 20240 

In Reply Refer To: 

FWS/DHRC/BRMS/028856 

David Cottingham 

Chief, Marine Mammal and Sea Turtle Division 

NOAA-Fisheries Office of Protected Resources 

13 15 East-West Highway 

Silver Spring, Maryland 209 10 

Dear Mr. Cottingham: 

The Fish and Wildlife Service has received your letter dated December 1,2006, concerning the 

preliminary Draft Programmatic Environmental Impact State (DPEIS) for the Marine Mammal 

Health and Stranding Response Program (MMHSRP). We appreciate the offer to serve as a 

cooperating agency and the opportunity to review this document in advance of its submission to 

the Environmental Protection Agency and subsequent publication of the Notice of Availability in 

the Federal Register. 

Unfortunately, due to resource limitations, the Service is unable to participate as a cooperating 

agency at this time on this DPEIS and should not be identified as such. In addition, we will not 

be able to review and provide comments on the DPEIS prior to its submission to the Federal 

Register. Instead, we will use the Federal Register public comment period as our opportunity to 

provide any comments. 

The Service supports collaborative efforts with NOAA-Fisheries for our joint responsibilities. 

We note that under the Marine Mammal Protection Act, with the exception of section 408, the 

MMHSFW is a program created and implemented by the Secretary of Commerce. The Service 

does not have the resourcers to provide an equivalent participation in this program. However, the 

Service will continue to work with NOAA-Fisheries as we finalize the associated Interim 

Standards for the Release of Rehabilitated Marine Mammals, which are identified as a part of the 

MMHSRP, and will provide input on any aspect of the DPEIS as it relates to the management of 

those marine mammals under the jurisdiction of the Secretary of the Interior during the public 

review process. 

TAKE PRIDE@(C~~ INAM ERICA- 
Mr. David Cottingham 2 

We look forward to our continued working relationship with NOAA-Fisheries on these and other 

issues that impact management of marine mammals. Please contact Martin Kodis, Chief of the 

Branch of Resource Management Support, at 703-358-2 16 1 with any questions. 

Sincerely, R 

Chief, 

Division of Habitat and Resource Conservation 
UNITE0 STATES DEPARTMENT OF COMMERCE 

National Oceanic and Atmospheric Administration 

NATIONAL MARINE FISHERIES SERVICE 

S~lver Spring, MD 2091 0 

JUN 2 2 2006 

James F. Devine 

U.S. Geological Survey 

12201 Sunrise Valley Drive 

Reston, VA 201 92 

Dear Mr. Devine: 

The National Marine Fisheries Service (NMFS) is working on an Environmental Impact 

Statement (EIS) for the Marine Mammal Health and Stranding Response Program (MMHSRP). 

Some activities of the MMHSRP are conducted under a permit issued under the MMPA and 

Section lO(a)(l)(A) of the Endangered Species Act (ESA) by the Permits, Conservation, and 

Education Division of the NMFS Office of Protected Resources. The current MMPAIESA 

permit expires on June 30,2007. A National Environmental Policy Act (NEPA) analysis of the 

activities covered under the permit must be completed prior to the issuance of a new permit. 

Potential future activities of the MMHSRP will also be analyzed in the EIS. 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The EIS is intended to satis@ the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

NMFS is the lead agency in the EIS process as defined in 40 CFR 1501 -5. We invite your 

participation as a cooperating agency in this effort. Cooperating agency responsibilities are 

outlined in 40 CFR 1501.6. The degree of your involvement in the process will be determined by 

the extent of your authority/responsibilities; your interest, expertise, and resource availability; 

and your commitments. We encourage your full participation in the EIS process withn the scope 

of your particular authority, responsibility, andtor expertise. This would include activities such 

as screening and evaluation of alternatives; information development; environmental, economic, 

or social analyses; and reviewing preliminary documents. However, at a minimum, we would 

request your assistance in developing information for the EIS within your expertise, as well as 

providing reviews of preliminary documents. 

@ Rinted on Recycled Papex 
We look forward to your response, which should include a point of contact for your agency. If 

you have any questions, please contact Ms. Sarah Howlett or Ms. Sarah Wilkin at (301) 713- 

2322. 

Sincerely, 

Stewart Harris 

Acting Chief, 

Marine Mammal and Sea Turtle Division 

Office of Protected Resources 

National Marine Fisheries Service 
United States Department of the Interior 

U. S. GEOLOGICAL SURVEY 

Reston, VA 201 92 

In Reply Refer To: 

Mail Stop 423 

June 29,2006 

Stewart Harris, Acting Chief 

Marine Mammal and Sea Turtle Division 

Office of Protected Resources 

National Marine Fisheries Service 

Silver Spring, Maryland 209 1 0 

Dear Mr. Harris, 

This is in response to your letter dated June 22,2006, requesting that the U.S. Geological Survey 

(USGS) participate as a Cooperating Agency on an Environmental Impact Statement (EIS) for 

the Marine Mammal Health and Stranding Response Program (MMHSRP). It is the policy of the 

USGS to decline requests to be an official Cooperating Agency in the NEPA activities of another 

Federal agency except where the proposed Federal action may directly affect our facilities or the 

conduct of our work. However, the Survey as part of our mission will continue to provide 

science support to other agencies when our data and scientific expertise have relevance to their 

proposed actions undergoing NEPA review. Such assistance could include attending or making 

presentations at scoping and technical meetings, and conducting special studies and data 

collection projects. 

If you have any question concerning our decision, you can contact me at (703) 648-4423 or 

Susan D. Haseltine, Associate Director of the USGS Biological Resources Discipline at (703) 

648-4050. 

Sincerely, 

Seni P Advisor for Science Applications 
THIS PAGE INTENTIONALLY LEFT BLANK 
UNITED STATES DEPARTMENT OF COMMERCE 

National Oceanic and Atmompharic Administration 

NATIONAL MARINE FISHERIES SERVICE 

Silver Spring, MD 209 1 0 

((Prefix)) ((First-Name)) ((Last-Name)) 

((Title)) 

((Organization-Name)) 

((Department)) 

((Address-1 u 

((Address-2)) 

((Address-3 )> 

Subject: Consistency Determination - Marine Mammal Health and Stranding Response 

Program Programmatic Environmental Impact Statement 

Dear ((Prefix)) ((Last-Name)): 

The National Oceanic and Atmospheric Administration's (NOAA) National Marine Fisheries Service 

(NMFS) is announcing the availability of a Draft Programmatic Environmental Impact Statement (PEIS) 

for the Marine Mammal Health and Stranding Response Program (MMHSRP). Preparation of the PEIS is 

being conducted in accordance with the National Environmental Policy Act (NEPA) of 1969 and the 

Council on Environmental Quality Regulations for Implementing NEPA (40 Code of Federal Regulations 

[CFR] 1500-1508). The Draft PEIS is enclosed and may also be downloaded from the NMFS Office of 

Protected Resources MMHSRP website at http://www.nmfs.noaa.gov/pr/health/eis. htm. 

Enclosed for review is NMFS' Consistency Determination under the Coastal Zone Management Act (16 

U.S.C. 145 1 et seq.) and 15 CFR Part 930, subpart C for the Proposed Actions and Preferred Alternatives 

associated with the MMHSRP. Please submit your state agency's concurrence with, or comments on, this 

Determination within 60 days &om the receipt of this letter (15 CFR 930.41) by one of the following 

methods: 

(1) By mail to: 

Mr. David Cottingham 

Chief, Marine Mammal and Sea Turtle Conservation Division 

Office of Protected Resources 

National Marine Fisheries Service 

13 15 East-West Highway 

Room 13635 

Silver Spring, MD 2091 0-3226 

(2) Or by fax to: (301) 427-2584 

(3) Or by e-mail to: mmhsrpeis.comrnents@noaa.gov 

If NMFS does not receive a reply from a state agency within 60 days from the receipt of the consistency 

determination and supporting information as required by 15 CFR 930.39(a) and there has not been an 

extension of the 60-day review period, then NMFS will assume concurrence. 
Thank you for your assistance. If you have any questions about the MMHSRP or the Draft PEIS, please 

contact Ms. Sarah Howlett or Ms. Sarah Wilkin at (301) 713-2322. 

Sincerely, 

David Cottingham 

Chief, 

Marine Mammal and Sea Turtle conservation Division 

Office of Protected Resources 

Enclosures: Consistency Determination and Draft PEIS 
 NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

This document provides the Alabama Department of Environmental Management (ADEM), 

Coastal Area Management Program with the National Marine Fisheries Service (NMFS) 

Consistency Determination under the Coastal Zone Management Act (CZMA) (16 U.S.C. 1451 et 

seq.) and 15 CFR Part 930, subpart C, for activities coordinated and conducted by the Marine 

Mammal Health and Stranding Response Program (MMHSRP). 

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. Under the Code of Alabama, Title 9, Chapter 7, Section 16, and pursuant to the CZMA (16 

U.S.C. 1452), ADEM is responsible for ensuring that Federal activities in the coastal zone are 

consistent to the maximum extent possible with the enforceable policies of the Alabama Coastal 

Area Management Program (ACAMP). Therefore, the PEIS will assess the impacts of the 

proposed alternatives on coastal resources within the context of ACAMP’s Provisions Relating to 

Coastal Activities (ADEM Administrative Code, Chapter 335, Division 8, Section 2). 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife to explore potential impacts to species protected under the ESA and the 

MMPA. A permit application for the MMHSRP activities involving ESA and MMPA species is 

currently being evaluated by the NMFS Office of Protected Resources Permits, Conservation and 

Education Division. 

However, at this time no significant impacts on Alabama’s coastal resources are anticipated. In 

accordance with ADEM Administrative Code 335-8-2 the preferred alternatives, with mitigation, 

would not adversely affect: historical, architectural or archeological sites; wildlife and fishery 

habitat; or public access to tidal and submerged lands, navigable waters and beaches or other 

public recreational resources. 
Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 

consistent to the maximum extent practicable with the enforceable policies of the ACAMP. The 

ACAMP has 60 days (plus any appropriate extension under 15 CFR 930.41(b)) from the receipt 

of this letter and accompanying information in which to concur with or object to the NMFS 

Consistency Determination. Concurrence will be presumed if the State’s response is not received 

by NMFS on the 60th day from receipt of this Determination. 
ALABAMA DEPARTMENT OFENVIRONMENTAL MANAGEMENT 

POST OFFICE Box 301463 361 30-1463 t 1400 COLISEUM BLVD. 361 10-2059 

MONTGOMERY, ALABAMA 

ONIS "TREY" GLENN, Ill,, P.E. WWW.ADEM.STATE.AL.US BOB RILEY 

DIRECTOR (334) 271-7700 GOVERNOR 

May 4, 2007 

David Cottingham 

Chief, Marine Mammal and Sea Turtle Conservation Division 

Office of Protected Resources 

National Marine Fisheries Service 

1315 East-West Highway 

Room 13635 

Silver Spring, MD 20910-3226 

Facsimiles: (334) 

Administration: 271-7950 

General Counsel: 3944332 

Comnication: 394-4383 

Air: 279-3044 

Land: 279-3050 

Water: 279-3051 

Groundwater: 270-5631 

Fid Operations: 272-8131 

Laboratory: 277-6718 

Mining: 3944326 

RE: Pro posed Federal Action : "DraR Programmatic Environmental Impact Statement (PEIS) for the Marine Mammal 

Health and Stranding Response Program (MMHSRP), " 

Dear Mr. Cottingham: 

Reference is made to the March 9, 2007 request submitted by the United States Department of Commerce National 

Oceanic and Atmospheric Administration, National Marine Fisheries Service, for the State of Alabama's coastal consistency 

determination regarding the referenced proposed draft programmatic environmental impad statement. A coastal 

consistency determination was requested pursuant to 15 CFR 5 930.41. 

The South Alabama Regional Planning Commission's (SARPC) advertisement of this proposed federal action by public 

notice has been completed. Based upon review of the information submitted with the request for coastal zone 

management consistency determination, it appears the proposed draft programmatic environmental impact statement 

would not result in significant negative impacts to Alabama's coastal resources pursuant to ADEM Administrative Code 

Rule 335-8-2-.O1 (2(b & c)). Therefore, the Alabama Department of Environmental Management has no objections to the 

National Marine Fisheries Service's statement of coastal consistency. 

If you have any questions, please contact Jennifer Robinson of the ADEM Coastal/Facility Section office in Mobile at 

2511432-6533 or jrobinson@adem.state.al.us. 

Sincerelv. , . 

Steven 0. Jenkins, Chief 

Field Operations Division 

Cc: Steve Heath - ADCNR-MRD Gulf Shores 

Bimingham Branch 

I1 0 Vulcan Road 

Birrringham, Alabama 35209-4702 

(205) 942-6168 

(205) 941 -1603 [Fax] 

Decatur Branch 

2715 Sandlin Road. S.W. 

Decatur. Alabama 35603-1333 

(256) 3551713 

(256) 340-9359 [Fax] 

Mobile Branch Mobile - Coastal 

2204 Perimeter Road 4171 Commanders Drive 

Mobile. Alabama 36615-1 131 Mobile. Alabama 36615-1421 

(251) 450-3400 (251) 432-6533 

(251) 479-2593 [Fax] (251 ) 432-6598 [Fax] Printed on Recyded Paper 
THIS PAGE INTENTIONALLY LEFT BLANK 
NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

This document provides the Alaska Department of Natural Resources, Office of Project 

Management and Permitting, Coastal Management Program with the National Marine Fisheries 

Service (NMFS) Consistency Determination under the Coastal Zone Management Act (CZMA) 

(16 U.S.C. 1451 et seq.) and 15 CFR Part 930, subpart C, for activities coordinated and conducted 

by the Marine Mammal Health and Stranding Response Program (MMHSRP).

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. Under Alaska’s Coastal Management Program Statute (Title 46, Chapter 39, Section 10), “the 

Department of Natural Resources shall render, on behalf of the state, all federal consistency 

determinations and considerations authorized by 16 U.S.C. 1456 (Section 307, Coastal Zone 

Management Act of 1972).” The PEIS will assess the impacts of the proposed alternatives on 

coastal resources that are provided under 1) the Standards of the Alaska Coastal Management 

Program (Alaska Administrative Code, Title 6, Chapter 80, Article 2, Uses and Activities) and 2) 

the Anchorage Coastal District Enforceable Policies. 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division. 

However, at this time, no significant impacts on Alaska’s coastal resources are anticipated. The 

preferred alternatives, with mitigation, are consistent with the enforceable policies regarding, 

marine habitats, water quality, coastal resources in subsistence areas, and cultural and 

architectural resources, and should present no foreseeable effects to these areas. 
Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 

consistent to the maximum extent practicable with the enforceable policies of the Alaska Coastal 

Management Program. 

The Alaska Coastal Management Program has 60 days (plus any appropriate extension under 15 

CFR 930.41(b)) from the receipt of this letter and accompanying information in which to concur 

with or object to the NMFS Consistency Determination. Concurrence will be presumed if the 

State’s response is not received by NMFS on the 60th day from receipt of this Determination. 
NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

This document provides the San Francisco Bay Conservation and Development Commission 

(BCDC) with the National Marine Fisheries Service (NMFS) Consistency Determination under 

the Coastal Zone Management Act (CZMA) (16 U.S.C. 1451 et seq.) and 15 CFR Part 930, 

subpart C, for activities coordinated and conducted by the Marine Mammal Health and Stranding 

Response Program (MMHSRP).

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. Under McAteer-Petris Act, the BCDC is authorized to prepare an enforceable plan to protect 

the San Francisco Bay and its shoreline. Under this authority, and pursuant to the CZMA, BCDC 

is responsible for ensuring that Federal activities in the coastal zone are consistent to the 

maximum extent possible with the enforceable policies of the San Francisco Bay Plan. The PEIS 

will assess the impacts of the proposed alternatives on coastal resources within the context of 

these policies. 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division. 

At this time, no significant impacts on San Francisco’s coastal resources are anticipated. The 

preferred alternatives, with mitigation, are consistent with enforceable policies regarding water 

quality, wetlands, tidal marshes, and tidal flatlands, and should present no foreseeable effects on 

these resources. 
Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 

consistent to the maximum extent practicable with the enforceable policies of the San Francisco 

Bay Plan. The BCDC has 60 days (plus any appropriate extension under 15 CFR 930.41(b)) from 

the receipt of this letter and accompanying information in which to concur with or object to the 

NMFS Consistency Determination. Concurrence will be presumed if the State’s response is not 

received by NMFS on the 60th day from receipt of this Determination. 
NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

This document provides the California Coastal Commission (Commission) with the National 

Marine Fisheries Service (NMFS) Consistency Determination under the Coastal Zone 

Management Act (CZMA) (16 U.S.C. 1451 et seq.) and 15 CFR Part 930, subpart C, for activities 

coordinated and conducted by the Marine Mammal Health and Stranding Response Program 

(MMHSRP).

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. Under the California Coastal Act of 1976 (Public Resources Code, Division 20, Section 

30330), the Commission is “designated as the state coastal zone planning and management 

agency for any and all purposes, and may exercise any and all powers set forth in the Federal 

Coastal Zone Management Act of 1972 (16 U.S.C. 1451, et seq.).” Therefore, all activities 

authorized, funded, or carried out by the Federal Government that affect coastal zone resources 

must be reviewed by the Commission for consistency with the federally approved California 

Coastal Management Program and the California Coastal Act. The PEIS will assess the impacts 

of the proposed alternatives on coastal resources that are provided under the California Coastal 

Act, Chapter 3, Coastal Resources Planning and Management Policies. 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division. 

However, at this time no significant impacts on California’s coastal resources are anticipated. 

The preferred alternatives, with mitigation, are consistent with enforceable policies regarding the 
marine environment, particularly Article 4, Section 30230, which states that “marine resources 

shall be maintained, enhanced, and where feasible, restored” and that “Uses of the marine 

environment should be carried out in a manner that will sustain the biological productivity of 

coastal waters and that will maintain healthy populations of all species of marine organisms...” 

Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 

consistent to the maximum extent practicable with the enforceable policies of the California 

Coastal Management Program. 

The California Coastal Management Program has 60 days (plus any appropriate extension under 

15 CFR 930.41(b)) from the receipt of this letter and accompanying information in which to 

concur with or object to the NMFS Consistency Determination. Concurrence will be presumed if 

the State’s response is not received by NMFS on the 60th day from receipt of this Determination. 
NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

This document provides the Commonwealth of Northern Mariana Islands (CNMI), Office of the 

Governor, Coastal Resources Management Office with the National Marine Fisheries Service 

(NMFS) Consistency Determination under the Coastal Zone Management Act (CZMA) (16 

U.S.C. 1451 et seq.) and 15 CFR Part 930, subpart C, for activities coordinated and conducted by 

the Marine Mammal Health and Stranding Response Program (MMHSRP).

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. Under Public Law 3-47, the Office of Coastal Resources Management is authorized to prepare 

an enforceable plan promote the conservation and wise development of coastal resources of the 

CNMI. Under this authority, and pursuant to the CZMA, the Office of Coastal Resources 

Management is responsible for ensuring that Federal activities in the coastal zone are consistent 

to the maximum extent possible with the enforceable policies of Title 15. The PEIS will assess 

the impacts of the proposed alternatives on coastal resources within the context of these policies. 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division. 

At this time, no significant impacts on CNMI coastal resources are anticipated. The preferred 

alternatives, with mitigation, would have no direct effects on areas of particular concern including 

shoreline, lagoon and reef, wetlands and mangrove, and coastal hazards areas. The MMHSRP is 

consistent with the goals of CNMI Public Law 3-47, the standards and policies in Title 15, 

Chapter 10, and federal water quality standards. 
Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 

consistent to the maximum extent practicable with the enforceable policies of the CNMI Coastal 

Resources Management program. The Office of Coastal Resources Management has 60 days 

(plus any appropriate extension under 15 CFR 930.41(b)) from the receipt of this letter and 

accompanying information in which to concur with or object to the NMFS Consistency 

Determination. Concurrence will be presumed if the State’s response is not received by NMFS 

on the 60th day from receipt of this Determination. 
NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

This document provides the Connecticut Department of Environmental Protection, Office of 

Long Island Sound Programs, Coastal Management Program with the National Marine Fisheries 

Service (NMFS) Consistency Determination under the Coastal Zone Management Act (CZMA) 

(16 U.S.C. 1451 et seq.) and 15 CFR Part 930, subpart C, for activities coordinated and conducted 

by the Marine Mammal Health and Stranding Response Program (MMHSRP). 

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. Under Connecticut’s Coastal Management Act, (Connecticut General Statute, Title 22a, 

Chapter 444, Section 96), the Department of Environmental Protection is granted the authority to 

“represent the state in formal proceedings regarding "federal consistency" as defined in the 

federal act,” and to “into written agreements with federal agencies concerning matters having an 

interest in or regulatory authority in the coastal area.” Such matters are to “provide for 

cooperation and coordination in the implementation of state and federal programs with 

jurisdiction in the coastal area in a manner consistent with (the Coastal Management Act) 

Sections 22a-90 to 22a-96, inclusive.” The PEIS will assess the impacts of the proposed 

alternatives on coastal resources that are provided under the Coastal Management Act and the 

Connecticut Coastal Manual. 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division. 

However, at this time, no significant impacts on Connecticut’s coastal resources are anticipated. 
The preferred alternatives, with mitigation, are consistent with the Coastal Management Act and 

would have no significant effects on beaches, dunes, shorelands, tidal wetlands, or archeological 

and paleontological resources. 

Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 

consistent to the maximum extent practicable with the enforceable policies of the Connecticut 

Coastal Management Program. The Connecticut Coastal Management Program has 60 days (plus 

any appropriate extension under 15 CFR 930.41(b)) from the receipt of this letter and 

accompanying information in which to concur with or object to the NMFS Consistency 

Determination. Concurrence will be presumed if the State’s response is not received by NMFS 

on the 60th day from receipt of this Determination. 
MAY-21-2887 89:86 DEP OLISP 868 424 4854 P.82/82 

S'I'Arl.'E OF CONNECTICUT 

DEPARTMENT OF ENVIRONME:NTAI, PKOTECrrION 

May I '7. 2007 

Ilavid Cottingham, Chiet' 

Ofici: of Protected Resources 

Marine Mammal and Sea Tunic C:onscrvalii'~rl I)ivi.citrn 

National Marine Fisheries Servicc 

13 15 East-Wusl Highway 

Silver Spring, MD 209 10 

Rc: Marinc M;~mmal Health and Stranding Responsr- Progrml; C:onsislency Concnr~enct: 

Dear Mr. Coltingharn: 

This is in rcsponse to your cor~sistency dcterrmination, rcccivctl on March 14, 2007, far the prolr(.r!,vfi 

Marine Mamnial Health and Str.;mrii~?g Rcsprmsc I"ingratn (MMIISRP). That rlctcnnilialion is requirccl i)v 

Section 307(c)(l) of the Coastal %iim Managcnicrrt I\~L of1,972, a!, arncnded. Sulrpart (: of 15 Codc 

I:ederal Regulations (CFR) Par1 9):;0, and Srctiorr II, Pnrl VIl(c) uf the State of Councctich~t C'oaslsi 

Marlagemerzt Program and Final El-ivironnientrtl In?p:icI ,. Ct. atonlent. 

The proposed pmgrarn wtrultl include issual-ii:c i.)i'rhu IJolitit.!.r uttd Rcvt lJrr~cric:esjtlr Muri~r~) 

iZ.I(~~rrnrtul Stnindirig Rc~spotz.~~., Rdrui>ilil~rtiot~, r~,/tlic.lc'irxc as final guidance; issuancti of a ncw 

Endangered Species Act (ESA)/Marinc Man7rnul IYr-r:utc~l.io~i Act (blVlPA) l?errnlt lo rhe MMHSRIv; 

continuation of currz~~l. re3pnni.c. rehiilrillti~lto~r, rclcasc, and rcsc;~rch nctivitics; ;1ni1 cunlinuation oi'llii: 

John PI. Prescott Marine M;~rnn~;tl Wrrcuc /\!;nistar~ct (.'ir":~nl. I1ro$rnin. This Ucpa~ln~ellt concurs with ::o~i; 

dctcmin:~tion that the pn)posed zrulion is coni;ixtant rn the ~uaxiinunr extenl prac~icablc wi~h Conncclicrr1:'h 

approved Coastal Managemenl I'ropam. pur-su;~~-~l lo 51,:c:lion 2:!;1~~~00(c) or thc Cor~riuciictrt Cenelal 

Statutes. 

Any fisheries tnanagcmcnt olatrs that lla\'c 3 potcnliul lo al'tkct thc Connecticul consla1 area. :is <t,i:!i 

as any related Environmcnlal Irrlpnct Yritten.rcnls ;and lir:g~rliito~.y Irnpucl Reviews, should l?e sent trr ivbiv 

Brian P. Thompson. Director otllu! LIEP Oflicc 01' l..i.rng Island Sorrnd I'rograms ;is carly as possiblo il! ihc 

cslahlishcd review period, after ~hc final coritcrrts cul'-rhi. clocn~ncrrti: Iiave lleetr detcrrrtincd. 

Commissioner 

GM/'I'O/to 

cc: Allison Castellan, OCRM 

Edward Parker, CT DEP 

David Simpson, CT DEI' 
THIS PAGE INTENTIONALLY LEFT BLANK 
NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

This document provides the Delaware Department of Natural Resources and Environmental 

Control (DNREC), Division of Soil and Water Conservation, Coastal Zone Program with the 

National Marine Fisheries Service (NMFS) Consistency Determination under the Coastal Zone 

Management Act (CZMA) (16 U.S.C. 1451 et seq.) and 15 CFR Part 930, subpart C, for activities 

coordinated and conducted by the Marine Mammal Health and Stranding Response Program 

(MMHSRP).

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. Under Delaware’s Coastal Zone Act (Delaware Code, Title 7, Chapter 70), DNREC is 

authorized to develop regulations regarding the development and use of Delaware’s coastal zone. 

Under this authority, and pursuant to the CZMA, DNREC is responsible for ensuring that Federal 

activities in the coastal zone are consistent to the maximum extent possible with the enforceable 

policies of the Delaware Coastal Management Program. These policies include the Coastal Zone 

Act, the Beach Preservation Act, the Wetlands Act, and the Subaqueous Lands Act. The PEIS 

will assess the impacts of the proposed alternatives on coastal resources within the context of 

these policies. 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division. 

However, at this time no significant impacts on Delaware’s coastal resources are anticipated. The 

preferred alternatives, with mitigation, are consistent with enforceable policies regarding 
wetlands, beach and coastal waters management, subaqueous lands, and should present no 

foreseeable effects on these resources. 

Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 

consistent to the maximum extent practicable with the enforceable policies of the Delaware 

Coastal Management Program. The Delaware Coastal Management Program has 60 days (plus 

any appropriate extension under 15 CFR 930.41(b)) from the receipt of this letter and 

accompanying information in which to concur with or object to the NMFS Consistency 

Determination. Concurrence will be presumed if the State’s response is not received by NMFS 

on the 60th day from receipt of this Determination. 
STATE OF DELAWARE 

DEPARTMENT OF NATURAL RESOURCES 81 EN.VIRONMENTA CONTROL 

DIVISION OF SOIL AND WATER CONSERVATION 

89 KINGS HIGHWAY 

DOVER, DELAWARE 1 a-1 

May 10,2007 

David Cottingham 

Marine Mammal and Sea Turtle Conservation Divisio 

National Marine Fisheries Service 

13 1 5 East-West Highway 

Room 13635 

Silver Spring, MD 209 10-3226 I 

RE: Delaware Coastal Management Federal Consistency Certification 

Marine Mammal Health and Stranding Response Program DraJt Programmatic Environmental 

Impact Statement 

Dear Mr. Cottingham: 

The Delaware Coastal Management Program (DCMP) has received and reviewed your consistency 

determination for the above referenced project. Based upon our review and pursuant to National 

Oceanic & Atmospheric Administration regulations (1 3 CFR 930), the DCMP concurs with your 

consistency determination for the Marine Mammal Health and Stranding Response Program Draft 

Programmatic Environmental Impact Statement. Our concurrence is based upon the restrictions 

and/or conditions placed on any and all permits issued to you for this project. 

If you have any questions regarding this determination please do not hesitate to contact me or Tricia 

Arndt of my staff at (302) 739-9283. 

ement Program 

cc: File 07.062 

Roy Miller-DFW 
THIS PAGE INTENTIONALLY LEFT BLANK 
NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

This document provides the Florida Department of Environmental Protection, Office of 

Intergovernmental Programs, Coastal Zone Management Program with the National Marine 

Fisheries Service (NMFS) Consistency Determination under the Coastal Zone Management Act 

(CZMA) (16 U.S.C. 1451 et seq.) and 15 CFR Part 930, subpart C, for activities coordinated and 

conducted by the Marine Mammal Health and Stranding Response Program (MMHSRP).

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. Under Florida’s Coastal Management Act (Title XXVIII, Chapter 380, Section 23), the Florida 

Department of Environmental Protection may review all “federal development projects and 

activities of federal agencies which significantly affect coastal waters and the adjacent shorelands 

of the state” to ensure that they “are conducted in accordance with the state's coastal management 

program.” The PEIS will assess the impacts of the proposed alternatives on coastal resources that 

are provided under the 23 State Statutes that compose the Florida Coastal Management Plan. 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division 

However, at this time no significant impacts on Florida’s coastal resources are anticipated. The 

preferred alternatives, with mitigation, are consistent with state policies regarding wildlife, water 

resources, state parks and preserves, environmental control, and historical and archeological 

resources, and should not present any foreseeable effects on these resources. 

Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 
consistent to the maximum extent practicable with the enforceable policies of the Florida Coastal 

Management Program. The Florida Coastal Management Program has 60 days (plus any 

appropriate extension under 15 CFR 930.41(b)) from the receipt of this letter and accompanying 

information in which to concur with or object to the NMFS Consistency Determination. 

Concurrence will be presumed if the State’s response is not received by NMFS on the 60th day 

from receipt of this Determination. 
Florida Department of 

Environmental Protection 

Marjory Stoneman Douglas Building 

3900 Commonwealth Boulevard 

X3llahassee. Florida 32333-3000 

Charlie Crist 

Governor 

leff Kottkamp 

Lt. Governor 

Michael W.. Sole 

Secretary 

May 22,2007 

Mr. David Cottingham, Chief 

Marine Mammal & Sea Turtle Conservation Division 

NOAA/National Marine Fisheries Service 

1315 East-West Highway, Room 13635 

Silver Spring, MD 20910-3226 

RE: National Marine Fisheries Service - Draft Programmatic Environmental Impact 

Statement (PEIS) for the Marine Mammal Health and Stranding Response Program 

(MMHSRP) - of Interest to the State of Florida. 

SAI # FL200703133137C 

Dear Mr. Cottingham: 

The Florida State Clearinghouse, pursuant to Presidential Executive Order 12372, 

Gubernatorial Executive Order 95-359, the Coastal Zone Management Act, 16 U.S.C. 9s 

1451-1464, as amended, and the National Environmental Policy Act, 42 U.S.C. $5 4321, 

4331-4335,4341-4347, as amended, has coordinated a review of the draft PEIS. 

Based on the information contained in the document submitted and comments provided 

by the Florida Fish and Wildlife Conservation Commission, the state has determined that 

the proposed federal action is consistent with the Florida Coastal Management Program. 

Thank you for the opportunity to review this proposal. Should you have any questions 

regarding this letter, please contact Ms. Lauren P. Milligan at (850) 245-2170. 

Yours sincerely, 

Sally B. Mann, Director 

Office of Intergovernmental Programs 

'*More Protection, Less Process 

www. dep. state. fl. us 
THIS PAGE INTENTIONALLY LEFT BLANK 
NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

This document provides Georgia Department of Natural Resources, Coastal Resources Division 

with the National Marine Fisheries Service (NMFS) Consistency Determination under the Coastal 

Zone Management Act (CZMA) (16 U.S.C. 1451 et seq.) and 15 CFR Part 930, subpart C, for 

activities coordinated and conducted by the Marine Mammal Health and Stranding Response 

Program (MMHSRP).

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. Under Georgia’s Coastal Management Act (Official Code of Georgia, Title 12, Chapter 5, 

Section 323), the Department of Natural Resources has the authority to “concur or object to a 

determination of consistency filed by a federal agency in connection with a federal activity based 

on the policies of the Georgia coastal management program....“ The PEIS will assess the impacts 

of the proposed alternatives on coastal resources that are provided under the Georgia Coastal 

Management Program Document and all state laws subject to the Federal Consistency provisions 

of the CZMA. 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division. 

However, at this time no significant impacts on Georgia’s coastal resources are anticipated. The 

preferred alternatives, with mitigation, are consistent with state policies regarding coastal 

marshlands, tidelands, protected areas, shore protection, and historic areas, and should not present 

any foreseeable effects on these resources. 
Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 

consistent to the maximum extent practicable with the enforceable policies of the Georgia Coastal 

Management Program. The Georgia Coastal Management Program has 60 days (plus any 

appropriate extension under 15 CFR 930.41(b)) from the receipt of this letter and accompanying 

information in which to concur with or object to the NMFS Consistency Determination. 

Concurrence will be presumed if the State’s response is not received by NMFS on the 60th day 

from receipt of this Determination. 
May 21,2007 

- 

Mr. David Cottingham, Chief Coastal Resources Division 

Marine Mammal and Sea Turtle Conservation Division 

Office of Protected Resources 

NOA.A/NMFS 

13 15 East West Highway 

Silver Spring, Maryland 209 10 

RE: Consistency Determination for Marine Mammal Health and Stranding Response Program 

Programmatic Environmental Impact Statement 

Dear Mr. Cottingham: 

Staff of the Coastal Management Program has reviewed your March 9,2007 letter and attached 

Programmatic Environmental Impact Statement on the above referenced action. The current 

Endangered Species Act / Marine Mammal Protection Act permit expires June 30,2007 and the 

EIS is required prior to issuance of a new permit. 

The Program concurs with your consistency determination. This determination ensures that the 

proposed project has been designed to comply to the maximum extent practicable with the 

applicable enforceable policies of the Georgia Coastal Management Program. 

Please feel fiee to contact Kelie Moore or me if we can be of further assistance. 

Sincerely, 

Susan Shipman 

Director 

cc: DNRlWRD/Nongame 

Georgia Department of Natural Resources Coastal Resources Division 

One Conservation Way Brunswick, Georgia 31520 

TEL (912) 264-7218 FAX: (912) 262-3143 WEB: http://crd.dnr.state.ga.us 
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NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

This document provides the Hawaii Department of Business, Economic Development and 

Tourism, Office of Planning, Coastal Zone Management Program with the National Marine 

Fisheries Service (NMFS) Consistency Determination under the Coastal Zone Management Act 

(CZMA) (16 U.S.C. 1451 et seq.) and 15 CFR Part 930, subpart C, for activities coordinated and 

conducted by the Marine Mammal Health and Stranding Response Program (MMHSRP).

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. Under Hawaii’s Coastal Zone Management Statute (Hawaii Revised Statues, Chapter 205A, 

Section 3), the Department of Business, Economic Development and Tourism, Office of Planning 

is authorized to “review federal programs, federal permits, federal licenses, and federal 

development proposals for consistency with the coastal zone management program.” The PEIS 

will assess the impacts of the proposed alternatives on coastal resources that are provided under 

Hawaii Revised Statues, Chapter 205A, Section 2, Coastal Zone Management Program, 

Objectives and Policies. 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division. 

However, at this time no significant impacts on Hawaii’s coastal resources are anticipated. The 

preferred alternatives, with mitigation, are consistent with enforceable state policies regarding 

coastal ecosystems, beach protection, marine resources, and historic resources, and should present 

no foreseeable effects in these areas. 
Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 

consistent to the maximum extent practicable with the enforceable policies of the Hawaii Coastal 

Management Program. The Hawaii Coastal Management Program has 60 days (plus any 

appropriate extension under 15 CFR 930.41(b)) from the receipt of this letter and accompanying 

information in which to concur with or object to the NMFS Consistency Determination. 

Concurrence will be presumed if the State’s response is not received by NMFS on the 60th day 

from receipt of this Determination. 
LINDA LINGLE 

GOVERNOR 

THEODORE E. LIU 

DIRECTOR 

MARK K. ANDERSON 

LAURA H. THI 

235 South Beretania Street, 6th Floor, Honolulu, Hawaii 96813 

Mailing Address: P.O. Box 2359, Honolulu, Hawaii 96804 

Ref. No. P-11761 

April 30,2007 

Mr. David Cottingham, Chief 

Marine Mammal and Sea Turtle Conservation Division 

Office of Protected Resources 

National Marine Fisheries Service 

13 15 East-West Highway, Room 13635 

Silver Spring, Maryland 209 10-3226 

Dear Mr. Cottingham: 

Subject: Hawaii Coastal Zone Management (CZM) Program Federal Consistenqy 

Review for Marine Mammal Health and Stranding Response Program 

The proposed actions and preferred alternatives associated with the Marine Mammal 

Health and Stranding Response Program (MMHSRP) have been reviewed for consistency with 

the Hawaii CZM Program. We concur with your determination that the activities coordinated 

and conducted by MMHSRP are consistent to the maximum extent practicable with the Hawaii 

CZM Program. 

CZM consistency concurrence is not an endorsement of the project nor does it convey 

approval with any other regulations administered by any State or County agency. Thank you for 

your cooperation in complying with the Hawaii CZM Program. If you have any questions, 

please call John Nakagawa of our CZM Program at (808) 587-2878. 

Director 

c: U.S. National Marine Fisheries Service, Pacific Area Office 

U.S. Fish and Wildlife Service, Pacific Islands Ecoregion 

Dr. Jeffrey Walters, HIHWNMS, Department of Land and Natural Resources 
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NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

This document provides the Louisiana Department of Environmental Resource, Office of Coastal 

Restoration and Management, Coastal Management Division with the National Marine Fisheries 

Service (NMFS) Consistency Determination under the Coastal Zone Management Act (CZMA) 

(16 U.S.C. 1451 et seq.) and 15 CFR Part 930, subpart C, for activities coordinated and conducted 

by the Marine Mammal Health and Stranding Response Program (MMHSRP). 

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. Under Louisiana’s State and Local Coastal Resources Management Act (Louisiana Revised 

Statutes, Title 49, Section 214.32), “any governmental body undertaking, conducting, or 

supporting activities directly affecting the coastal zone shall ensure that such activities shall be 

consistent to the maximum extent practicable with the state program and any affected approved 

local program having geographical jurisdiction over the action.” The PEIS will assess the 

impacts of the proposed alternatives on coastal resources in accordance with the policies 

enumerated in Louisiana Administrative Code (L.A.C.), Title 43, Chapter 7, Section 701, 

Guidelines Applicable to All Uses. 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division. 
However, at this time, no significant impacts on Louisiana’s coastal resources are anticipated. 

The preferred alternatives, with mitigation, are consistent with the guidelines listed in 43 L.A.C 

701 regarding beaches, barrier islands, wildlife and aquatic habitats, and historic and cultural 

resources. 

Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 

consistent to the maximum extent practicable with the enforceable policies of the Louisiana 

Coastal Management Program. The Louisiana Coastal Management Program has 60 days (plus 

any appropriate extension under 15 CFR 930.41(b)) from the receipt of this letter and 

accompanying information in which to concur with or object to the NMFS Consistency 

Determination. Concurrence will be presumed if the State’s response is not received by NMFS 

on the 60th day from receipt of this Determination. 
KATHLEEN BABINEAUX BLANCO 

GOVERNOR 

SCOTT A. ANGELLE 

SECRETARY 

DEPARTMENT OF NATURAL RESOURCES 

OFFICE OF COASTAL RESTORATION AND MANAGEMENT 

April 17,2007 

David Cottingham, Chief 

Marine Mammal and Sea Turtle Conservation Division 

Office of Protected Resources 

National Marine Fisheries Service 

National Oceanic and Atmospheric Administration 

13 15 East-West Highway 

Silver Springs, MD 209 1 0 I 

RE: C20070156, Coastal Zone Consistency 

National Oceanic and Atmospheric Administration 

Direct Federal Action 

Draft Programmatic Environmental Impact Statement for the Marine Mammals Health 

and Stranding Response Program, Offshore Louisiana. 

Dear Mr. Cottingham: 

The above referenced project has been reviewed for consistency with the approved Louisiana Coastal 

Resource Program (LCRP) as required by Section 307 ofthe Coastal Zone Management Act of 1972, 

as amended. The project, as proposed in the application, is consistent with the LCRP. If you have 

any questions concerning this information request, please contact Agaha Brass of the Consistency 

Section at (225)342-9425 or 1-800-267-401 9. 

Sincerely, 

Acting Administrator 

CC. Roy Crabtree, NMFS, St. Petersburg, FL 

Heather Finley, LDWF 

COASTAL MANAGEMENT DIVISION P. 0. BOX 44487 BATON ROUGE. LA 70804-4487 

PHONE (225) 342-7591 FAX (225) 342-9439 WEB http://www.dnr.state.la.us 

AN EQUAL OPPORTUNITY EMPLOYER 
THIS PAGE INTENTIONALLY LEFT BLANK 
NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

 

This document provides the Maine State Planning Office, Coastal Program with the National 

Marine Fisheries Service (NMFS) Consistency Determination under the Coastal Zone 

Management Act (CZMA) (16 U.S.C. 1451 et seq.) and 15 CFR Part 930, subpart C, for activities 

coordinated and conducted by the Marine Mammal Health and Stranding Response Program 

(MMHSRP).

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. Under Maine Revised Statute (Annotated) (M.R.S.A.), Title 38, Chapter 19, Section 1801, 

“state and local agencies and federal agencies with responsibility for regulating, planning, 

developing or managing coastal resources, shall conduct their activities affecting the coastal area 

consistent with the following policies....” The Statute then enumerates several enforceable 

policies that are further delineated by the federally-approved Maine Coastal Program. The PEIS 

will assess the impacts of the proposed alternatives on coastal resources that are provided under 

38 M.R.S.A. 1801 and the “Maine Guide to Federal Consistency Review.” 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division. 

However, at this time, no significant impacts on Maine’s coastal resources are anticipated. The 

preferred alternatives, with mitigation, are consistent with policies pertaining, but not limited to, 

water quality, recreation and tourism, and marine resource management, and should present no 
foreseeable effects in these areas. 

Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 

consistent to the maximum extent practicable with the enforceable policies of the Maine Coastal 

Program. The Maine Coastal Program has 60 days (plus any appropriate extension under 15 CFR 

930.41(b)) from the receipt of this letter and accompanying information in which to concur with 

or object to the NMFS Consistency Determination. Concurrence will be presumed if the State’s 

response is not received by NMFS on the 60th day from receipt of this Determination. 
NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

This document provides the Maryland Department of the Environment (MDE), Wetlands and 

Waterways Program, Coastal Zone Consistency Division with the National Marine Fisheries 

Service (NMFS) Consistency Determination under the Coastal Zone Management Act (CZMA) 

(16 U.S.C. 1451 et seq.) and 15 CFR Part 930, subpart C, for activities coordinated and conducted 

by the Marine Mammal Health and Stranding Response Program (MMHSRP).

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. Maryland Executive Order 01.01.1978.05 establishes the state’s CZMP and grants the 

Maryland Department of Natural Resources the authority to administer the program. Under this 

authority, and pursuant to the CZMA, the MDE Coastal Zone Consistency Division is responsible 

for ensuring that Federal activities in the coastal zone are consistent to the maximum extent 

possible with the enforceable policies of the Maryland CZMP. The PEIS will assess the impacts 

of the proposed alternatives on coastal resources within the context of the Maryland CZMP’s 

Goals. 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division. 

However, at this time, no significant impacts on Maryland’s coastal resources are anticipated. 

The preferred alternatives, with mitigation, support the Maryland CZMP’s goals by protecting 

coastal land and water habitats and preserving historic and cultural resources. 
Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 

consistent to the maximum extent practicable with the enforceable policies of the Maryland 

CZMP. The MDE Coastal Zone Consistency Division has 60 days (plus any appropriate 

extension under 15 CFR 930.41(b)) from the receipt of this letter and accompanying information 

in which to concur with or object to the NMFS Consistency Determination. Concurrence will be 

presumed if the State’s response is not received by NMFS on the 60th day from receipt of this 

Determination. 
NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

This document provides the Massachusetts Executive Office of Environmental Affairs, Office of 

Coastal Zone Management (CZM) with the National Marine Fisheries Service (NMFS) 

Consistency Determination under the Coastal Zone Management Act (CZMA) (16 U.S.C. 1451 et 

seq.) and 15 CFR Part 930, subpart C, for activities coordinated and conducted by the Marine 

Mammal Health and Stranding Response Program (MMHSRP).

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. According to the Massachusetts Coastal Zone Management Program Federal Consistency 

Review Regulations (Code of Massachusetts Regulation, Title 301, Chapter 21, Section 6), CZM 

is responsible for “determining the consistency, to the maximum extent practicable, of federal 

activities in or affecting the Massachusetts Coastal Zone with CZM policies.” The PEIS will 

assess the impacts of the proposed alternatives on coastal resources with the enforceable policies 

that are enumerated in 301 CMR 21.98 and the federally-approved CZM Program Plan. 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division. 

However, at this time, no significant impacts on Massachusetts’ coastal resources are anticipated. 

The preferred alternatives, with mitigation, are consistent with CZM policies pertaining to water 

quality, habitat, and protected areas, and should not present any foreseeable effects on these 

resources. 
Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 

consistent to the maximum extent practicable with the enforceable policies of the Massachusetts 

Coastal Management Program. The Massachusetts Coastal Management Program has 60 days 

(plus any appropriate extension under 15 CFR 930.41(b)) from the receipt of this letter and 

accompanying information in which to concur with or object to the NMFS Consistency 

Determination. Concurrence will be presumed if the State’s response is not received by NMFS 

on the 60th day from receipt of this Determination. 
NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

This document provides the Mississippi Department of Marine Resources with the National 

Marine Fisheries Service (NMFS) Consistency Determination under the Coastal Zone 

Management Act (CZMA) (16 U.S.C. 1451 et seq.) and 15 CFR Part 930, subpart C, for activities 

coordinated and conducted by the Marine Mammal Health and Stranding Response Program 

(MMHSRP).

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. Under Mississippi Code, Title 57, Chapter 15, Section 6, the Mississippi Marine Resources 

Council (Council) is “directed to prepare and implement a coastal program.” Under this 

authority, and pursuant to the CZMA, the Council is responsible for ensuring that Federal 

activities in the coastal zone are consistent to the maximum extent possible with the enforceable 

policies of the Mississippi Coastal Program. The PEIS will assess the impacts of the proposed 

alternatives on coastal resources within the context of the policies enumerated in Mississippi 

Code, Sections 39-7-3, 49-15-1, 49-17-3, 49-27-3 and 51-3-1. 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division 

However, at this time, no significant impacts on Mississippi’s coastal resources are anticipated. 

The preferred alternatives, with mitigation, are consistent with the Mississippi Coastal Program’s 

policies in that it protects aquatic life, coastal wetlands, water quality, and historical and 

archeological resources. 
Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 

consistent to the maximum extent practicable with the enforceable policies of the Mississippi 

Coastal Program. The Mississippi Coastal Program has 60 days (plus any appropriate extension 

under 15 CFR 930.41(b)) from the receipt of this letter and accompanying information in which 

to concur with or object to the NMFS Consistency Determination. Concurrence will be presumed 

if the State’s response is not received by NMFS on the 60th day from receipt of this 

Determination. 
MISSISSIPPI 

DEPARTMENT OF MARINE RESOURCES 

March 15,2007 

David Cottingham, Chief 

Marine Mammal and Sea Turtle Conservation Divisio 

Office of Protected Resources P 

n 

National Marine Fisheries Service 

13 15 East-West Highway, Room 13635 

Silver Springs, MD 209 10-3226 

Subject: Proposed Draft PEIS 

DMR File 070428 

Dear Mr. Cottingham: 

The State of Mississippi has completed its review of the consistency determination for the abovereferenced proposed Draft Programmatic Environmental Impact Statement for the Marine 

Mammal Health and Stranding Response Program under the Coastal Zone Management Act of 

1972 (as amended). The Department of Marine Resources, as the lead coastal program agency for 

the State of Mississippi pursuant to 16 U.S.C. Sec ion 1456(c) and Section 57-15-5 of the 

Mississippi Code, concurs with the National Marine ishery I Service's consistency certification 

for this action. The actions described in the text of the proposed rule have been determined to be 

consistent to the maximum extent practicable with the Mississippi Coastal Program. 

If you have any questions about this correspondence, please do not hesitate to contact us. 

Sincerely, 

Willa Henriksen 

Bureau Director, Wetlands Permitting 

cc: MS Clearinghouse Officer 

1141 Bayview Avenue Biloxi, MS 39530-1613 Tel: (228) 374-5000 www.dmr.state.ms.us 

An Equal Opportunity Employer 
THIS PAGE INTENTIONALLY LEFT BLANK 
NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

This document provides the New Hampshire Department of Environmental Services (DES), 

Coastal Program with the National Marine Fisheries Service (NMFS) Consistency Determination 

under the Coastal Zone Management Act (CZMA) (16 U.S.C. 1451 et seq.) and 15 CFR Part 930, 

subpart C, for activities coordinated and conducted by the Marine Mammal Health and Stranding 

Response Program (MMHSRP).

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. The DES currently administers the New Hampshire Coastal Program. As such, DES is 

responsible for ensuring that direct federal activities are conducted in a manner that is consistent 

to the maximum extent practicable with the state coastal management program. The PEIS will 

assess the impacts of the proposed alternatives on coastal resources in accordance with the 

enforceable policies delineated in the New Hampshire Coastal Program Final EIS. 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division. 

However, at this time, no significant impacts on New Hampshire’s coastal resources are 

anticipated. The preferred alternatives, with mitigation, are consistent with policies pertaining 

coastal resources, recreation and public access, and historic and cultural resources, and should 

present no foreseeable effects in these areas. 

Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 
consistent to the maximum extent practicable with the enforceable policies of the New Hampshire 

Coastal Program. The New Hampshire Coastal Program has 60 days (plus any appropriate 

extension under 15 CFR 930.41(b)) from the receipt of this letter and accompanying information 

in which to concur with or object to the NMFS Consistency Determination. Concurrence will be 

presumed if the State’s response is not received by NMFS on the 60th day from receipt of this 

Determination. 
The State of New Hampshire 

DEPARTMENT OF ENVIRONMENTAL SERVICES 

Thomas S. Burack, Commissioner 

April 16,2007 

David Cottingham, Chief 

Marine Mammal & Sea Turtle Conservation Division 

Office of Protected Resources 

National Marine Fisheries 'Service 

13 15 East-West Highway 

Silver Spring, MD 209 10-3226 

RE: File No. 2007-09; Marine Mammal Health and Stranding Response Program Draft 

Programmatic Environmental Impact Statement 

Dear Mr. Cottingham: 

The New Hampshire Coastal Program (NHCP) has received the National Marine Fisheries 

Service's federal consistency determination for the Marine Mammal Health and Stranding 

Response Program Draft Programmatic Environmental Impact Statement (PEIS), pursuant to 

Section 307(c)(l) of the Coastal Zone Management Act, 16 U.S.C. 5 1456(c)(l). After 

reviewing the draft PEIS, we find it to be consistent, to the maximum extent practicable, with the 

enforceable policies of the NHPC's federally approved coastal management program. 

Should you have any questions, please feel free to contact me at (603) 559-0025 

Sincerely,, 

Christian P. Williams 

Federal Consistency Coordinator 

New Hampshire Coastal Program 

DES Web site: www.des.nh.gov 

50 International Drive, Suite 200, Portsmouth, New Hampshire 03801 

Telephone: (603) 559-1500 Fax: (603) 559-1510 TDD Access: Relay NH 1-800-735-2964 
THIS PAGE INTENTIONALLY LEFT BLANK 
NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

This document provides the New Jersey Department of Environmental Protection (DEP), Office 

of Policy, Planning and Science, Coastal Management Program with the National Marine 

Fisheries Service (NMFS) Consistency Determination under the Coastal Zone Management Act 

(CZMA) (16 U.S.C. 1451 et seq.) and 15 CFR Part 930, subpart C, for activities coordinated and 

conducted by the Marine Mammal Health and Stranding Response Program (MMHSRP).

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. Under New Jersey’s Coastal Zone Management Rules (NJ Administrative Code, Title 7, 

Chapter 7E, Section 1.2(e)), DEP has the authority to determine “the consistency or compatibility 

of proposed actions by Federal, State and local agencies within or affecting the coastal zone, 

including, but not limited to, determinations of Federal consistency under Section 307 of the 

Federal Coastal Zone Management Act....” The PEIS will assess the impacts of the proposed 

alternatives on coastal resources in accordance with the Coastal Zone Management Rules. 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division. 

However, at this time, no significant impacts on New Jersey’s coastal resources are anticipated. 

The preferred alternatives, with mitigation, are consistent with New Jersey State law and 

consistent with the policies enumerated in the Coastal Zone Management Rules (NJAC 7:7E-1.5) 

in that they protect the health and safety of the public and protect and enhance the coastal 

ecosystem. 
Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 

consistent to the maximum extent practicable with the enforceable policies of the New Jersey 

Coastal Management Program. The New Jersey Coastal Management Program has 60 days (plus 

any appropriate extension under 15 CFR 930.41(b)) from the receipt of this letter and 

accompanying information in which to concur with or object to the NMFS Consistency 

Determination. Concurrence will be presumed if the State’s response is not received by NMFS 

on the 60th day from receipt of this Determination. 
NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

This document provides the New York Department of State, Division of Coastal Resources with 

the National Marine Fisheries Service (NMFS) Consistency Determination under the Coastal 

Zone Management Act (CZMA) (16 U.S.C. 1451 et seq.) and 15 CFR Part 930, subpart C, for 

activities coordinated and conducted by the Marine Mammal Health and Stranding Response 

Program (MMHSRP).

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. Under New York’s Waterfront Revitalization and Coastal Resources Act (New York State 

Executive Law 42, Section 912), it is New York state policy to ensure consistency of federal 

actions with “policies of the coastal area and inland waterways, and with accepted waterfront 

revitalization programs of the area defined or addressed by such programs.” The PEIS will assess 

the impacts of the proposed alternatives on coastal resources within the context of the policies 

described in Part II, Section 6 of the New York Coastal Management Program (CMP) document. 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division. 

However, at this time, no significant impacts on New York’s coastal resources are anticipated. 

The preferred alternatives, with mitigation, are consistent with CMP policies regarding fish and 

wildlife, historic and scenic resources, water resources, and wetlands, and should not present any 

foreseeable effects on these resources. 
Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 

consistent to the maximum extent practicable with the enforceable policies of the New York 

Coastal Management Program. The New York Coastal Management Program has 60 days (plus 

any appropriate extension under 15 CFR 930.41(b)) from the receipt of this letter and 

accompanying information in which to concur with or object to the NMFS Consistency 

Determination. Concurrence will be presumed if the State’s response is not received by NMFS 

on the 60th day from receipt of this Determination. 
May 2 1,2007 

Mr. David Cottingham 

Office of Protected Resources 

National Marine Fisheries Service 

13 15 East-West Highway 

Room 13635 

Silver Spring, MD 209 10-3226 

Re: F-2006-0261 DA 

NOAA 1 National Marine Fisheries Service 

Marine Mammal Health and Stranding Response 

Program 

Concurrence with Consistencv Determination 

Dear Mr. Cottingham: 

The Department of State has completed its review of the National Marine Fisheries Service's consistency 

determination regarding the consistency of the Marine Mammal Health and Stranding Response Program 

with the New York State Coastal Management Program. 

Based upon the information submitted, the Department of State concurs with the National Marine Fisheries 

Service's consistency determination regarding this matter. 

sally BalkDeputy Director 

Division of Coastal Resources 
THIS PAGE INTENTIONALLY LEFT BLANK 
NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

This document provides the North Carolina Department of Environment and Natural Resources, 

Division of Coastal Management with the National Marine Fisheries Service (NMFS) 

Consistency Determination under the Coastal Zone Management Act (CZMA) (16 U.S.C. 1451 et 

seq.) and 15 CFR Part 930, subpart C, for activities coordinated and conducted by the Marine 

Mammal Health and Stranding Response Program (MMHSRP). 

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. Under North Carolina’s Administrative Code, Title 15A, Chapter 7A, “the purpose of the 

Division of Coastal Management is to “provide staff support to the Secretary of Environment, 

(Health) and Natural Resources...in the administration of the Coastal Area Management Act of 

1974 and North Carolina’s participation in the Federal Coastal Zone Management Act of 1972.” 

As such, the Division is responsible for ensuring that Federal activities in the coastal zone are 

consistent to the maximum extent possible with the enforceable policies of the North Carolina 

Coastal Management Program. The PEIS will assess the impacts of the proposed alternatives on 

coastal resources within the context of the Coastal Area Management Act (CAMA) (NC General 

Statute, Article 7, Chapter 113A, Sections 100-134.3). 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division. 

However, at this time, no significant impacts on North Carolina’s coastal resources are 

anticipated. In accordance with CAMA policies on development and use of Estuarine and Ocean 
Systems, the preferred alternatives, with mitigation conserve the biological, economic, and social 

values of coastal wetlands, estuarine waters, and public trust areas and would not cause major or 

irreversible damage to valuable archeological or historic resources 

Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 

consistent to the maximum extent practicable with the enforceable policies of the North Carolina 

Coastal Management Program. The North Carolina Coastal Management Program has 60 days 

(plus any appropriate extension under 15 CFR 930.41(b)) from the receipt of this letter and 

accompanying information in which to concur with or object to the NMFS Consistency 

Determination. Concurrence will be presumed if the State’s response is not received by NMFS 

on the 60th day from receipt of this Determination. 
North Carolina Department of Environment and Natural Resources 

Division of Coastal Management 

Michael F. Easley, Governor Charles S. Jones, Director William G. Ross Jr., Secretary 

April 10,2007 

David Cottingham, Chief , 

Marine Mammal and Sea Turtle Conservation Divi$ion 

National Marine Fisheries Service I 

Room 13635 

13 1 5 East- West Highway 

Silver Spring, MD 209 10-3226 

SUBJECT: CD07-014 - Consistency for the Proposed Marine Mammal 

Health and Stranding (DCM#20070023) 

Dear Mr. Cottingham: 

The Division of Coastal Management received (M ch 12,2007) a consistency determination 

from the National Marine Fisheries Service (NMFS finding that the proposed implementation 

of the Marine Mammal Health and Stranding Resp 1 nse Program would be consistent with the 

State's coastal management program. North Caroli a's coastal zone management program 

consists of, but is not limited to, the Coastal Area anagement Act, the State's Dredge and 

Fill Law, Chapter 7 of Title 15A of North Carolina's Administrative Code, and the land use 

plan of the County and/or local municipality in whi h the proposed project is located. It is the 

objective of the Division of Coastal Management ( CM) to manage the State's coastal 

waters. 

resources to ensure that proposed Federal activities 

i 

would be compatible with safeguarding 

and perpetuating the biological, social, economic, d aesthetic values of the State's coastal 

To solicit public comments, DCM circulated a description of the proposed project to State 

agencies that would have a regulatory interest. No asserting that the proposed 

activity would be inconsistent with the State's program were received. A 

copy of each response received has been 

DCM has reviewed the submitted information to the management objectives and 

enforceable policies of Subchapters 7H and 7 of Title 15A of North Carolina's 

Administrative Code which are a part of the coastal management program 

and concurs that the proposed Federal the maximum extent 

practicable, with the enforceable management program. 

400 Commerce Avenue, Morehead City, North Carolina 28557-3421 

Phone: 252-808-2808 \ FAX: 252-247-3330 \ lnthnet: www.nccoastalmanagement.net 

An Equal Opportunity \Affirmative Action Employer - 50% Recycled \ 10% Post Consumer Paper 
Should the proposed action be modified, a revised bonsistency determination could be 

necessary. This might take the form of either a sup lemental consistency determination 

pursuant to 15 CFR 930.46, or a new consistency d termination pursuant to 15 CFR 930.36. 

Likewise, if further project assessments reveal envi onmental effects not previously 

considered by the proposed action, a supplemental onsistency certification 

1 may be required. 

If you have any questions, please contact Stephen ynas at 252-808-2808. Thank you for 

your consideration of the North Carolina Coastal Management Program. 

Sincerely, 

Chqles S. Jones ./ 

Mike Street, NC Division of Marine Fisheries 

Steve Everhart, NC Wildlife Resources Comrnissic 

Page: 2 
North Carolina Department of Environment and Natural Resources 

Division of Coastal Management ' 

Michael F. Easley, Governor Charles S. Jones, Director William G. Ross Jr., Secretary 

FIIQM: 

SUBJECT: 

Steve Evcrl~art 

Division ~f 111land Fisheries, 1 Jabrtat Conservrttion. Program 

NC Wildlife Resources Coummission 

127 Cardinal Drivc Extension ~ , , 

Wilmington, NC 28405-5406 ,* 

Stephen Rynas, AICP: Fcderol Consi$tcncy Coordinator ' 

I'roposcd Implcmcntation of a Marincl Marninal Hcnlth and SI 

(DGM#20070023) 

LOCATION: Offshore Coastal North Carolina 

'I'bc ahovc ltstcd docunlent is bcin9 circ~tlatcd for consiste~~cy rcvi~w and comlncnt by April 6,2007. 

Your responses \\ill assist us in dctcrlnining ahctl~cr ttio proposcd project would bc consistent wit11 thc 

Statc's Coa&il Matti~lagcmont Program. If the proposcd projcct docs not confornl to your rcquirctncnts, 

plcasc idcutiFy Ihc rncasurcs that \\odd bc necessary to bring thc proposcdprojcct into confom1mce. If 

you I~avc ally additional ql~estions resarding the proposcd projcct you nuy colitact mnc at 252-808-2808. 

REPLY 

No Comment. 

This oRicc supports the projcct as proposcd. 

Co~nincnts to this prqjcct are attached. 

Signed: hte: 

CORRECTIONS 

I'l~~sc idcrdiQ any comctia~~s, fidhtlons, or dclchuns tlut should bc nlr~dc in t~nm of wfdact inCornlttlion 

RETGRN CORlPLETEU FORM 

to 

S1Cphm Rwus, fkJcr;II Cmtsislelcy Cwr~1in:lalor 

NC IXvisiolr of Coustlll h.latragunci~r 

J(X) Cornm~rce Armue 

Murc11end City, PIC 28557-381 
Michael F. Easley, Governor Division of Marine Fisheries Dr. Louis B. Daniel Ill, Director 

William G. Ross Jr., Secretary 

MEMORANDUM 

APR 9 20@7 

TO: Stephen Rynas 

Federal Consistency Coordinator Morehead City DCM 

FROM Mike Street bm ~fi h& 6w 

DATE: April 5, 2007 

SUBJECT: Proposed lmple~nentation of a Marine Mammal Health and Stranding Response 

Program (DCM#i20070023) 

Attached is the Divisions' reply for the above referenced project. If you have any questions, 

please do not hesitate to co~itact me. 

3441 Arendell Street, P.O. Box 769, Morehead City, North Carolina 28557 

Phone: 252 726-7021 \ FAX: 252 727-5127 \ Internet: www.ncdmf.net 

An Equal Opportunity I Affirmative Action Employer - 50 % Recycled \ 10% post Consumer Paper 
North Carolina Department of Environment and Natural Reso 

~ivision of Coastal Management M 

Michael F. Easley, Governor Charles S. Jones, Director %($$eflds ~i&~

TO: 

FROM: 

Mike Street 

NCDENR - Division of Marine Fisher es 

P.O. Box 769 1 

Morehead City, NC 28557-0769 

Stephen Rynas, AICP; Federal Consis~ency Coordinator 

SUBJECT: Proposed Implementation of a Marine Mammal Health and Stranding Response Program 

(DCM#20070023) 

LOCATION: Offshore Coastal North Carolina 

The above listed document is being circulated for consistency review and comment by April 6, 2007. 

Your responses will assist us in determining whether the proposed project would be consistent with the 

State's Coastal Management Program. If the proposed project does not conform to your requirements, 

please identifl the measures that would be necessary to bring the proposed project into conformance. If 

you have any additional questions regarding the proposed project you may contact me at 252-808-2808. 

Comments to this project are attached. 

No Comment. 

This ofice supports the project as prodosed. 

Date: ~$b 7/0,7 

This office objects to the project as pr~posed. 

Signed: 

CORRECTIONS 

Please identify any corrections, additions, or deletions that should be made in terms of contact information. 

RETURN COMPLETED FORM 

to 

Stephen Rynas, Federal Cansistency Coordinator 

NC Division of Coastal Management 

400 Commerce Avenue 

Morehead City, NC 28557-3421 
THIS PAGE INTENTIONALLY LEFT BLANK 
NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

This document provides the Oregon Department of Land Conservation and Development 

(DLCD), Coastal Management Program with the National Marine Fisheries Service (NMFS) 

Consistency Determination under the Coastal Zone Management Act (CZMA) (16 U.S.C. 1451 et 

seq.) and 15 CFR Part 930, subpart C, for activities coordinated and conducted by the Marine 

Mammal Health and Stranding Response Program (MMHSRP).

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. Under Oregon Revised Statute 196, Section 435, the DLCD is the “designated Coastal 

Management Agency for purposes of carrying out and responding to the Coastal Zone 

Management Act of 1972.” As such, under the provisions of Oregon Administrative Code 660, 

Division 35, Section 20, “all consistency determinations, consistency certifications and proposals 

for federal assistance shall be sent to and reviewed by (DLCD) for consistency with the approved 

Oregon Coastal Management Program.” The PEIS will assess the impacts of the proposed 

alternatives on coastal resources in accordance with the Statewide Planning Goals (Goals 16-19) 

that comprise the Oregon Coastal Management Program. 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division. 

However, at this time, no significant impacts on Oregon’s ocean and coastal resources are 

anticipated. The preferred alternatives, with mitigation, are consistent with Goal 16 (Estuarine 

Resources) and 17 (Coastal Shorelands) in that it is a use that maintains the integrity of estuarine 
and coastal waters. It is consistent with Goals 18 (Beaches and Dunes) and 19 (Ocean Resources) 

in that it protects beaches and dunes and encourages the beneficial uses of ocean resources. 

Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 

consistent to the maximum extent practicable with the enforceable policies of the Oregon Coastal 

Management Program. The Oregon Coastal Management Program has 60 days (plus any 

appropriate extension under 15 CFR 930.41(b)) from the receipt of this letter and accompanying 

information in which to concur with or object to the NMFS Consistency Determination. 

Concurrence will be presumed if the State’s response is not received by NMFS on the 60th day 

from receipt of this Determination. 
NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

This document provides the Pennsylvania Department of Environmental Protection (DEP), Water 

Planning Office with the National Marine Fisheries Service (NMFS) Consistency Determination 

under the Coastal Zone Management Act (CZMA) (16 U.S.C. 1451 et seq.) and 15 CFR Part 930, 

subpart C, for activities coordinated and conducted by the Marine Mammal Health and Stranding 

Response Program (MMHSRP).

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

 

2. Under Pennsylvania Code Title 4 Chapter 1 Subchapter EE, the Pennsylvania DEP is 

designated as the lead agency for implementing and administering the Federal Coastal Zone 

Management Program for the Commonwealth of Pennsylvania. The PEIS will assess the impacts 

of the proposed alternatives on coastal resources of Pennsylvania. 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division. 

However, at this time no impacts on Pennsylvania’s coastal resources are anticipated from the 

preferred alternatives (with mitigation). Based upon the preceding information, data and analysis, 

NMFS finds that the MMHSRP is consistent to the maximum extent practicable with the 

enforceable policies of Pennsylvania's approved coastal management program that are provided 

in the Chapters 2 and 4 and Appendix A of the Commonwealth of Pennsylvania’s Coastal Zone 

Program Guidance Document. The Pennsylvania DEP has 60 days (plus any appropriate 

extension under 15 CFR 930.41(b)) from the receipt of this letter and accompanying information 
in which to concur with or object to the NMFS Consistency Determination. Concurrence will be 

presumed if the State’s response is not received by NMFS on the 60th day from receipt of this 

Determination. 
Pennsylvania Department of Environmental Protection 

Rachel Carson State Office Building 

P.O. Box 2063 

Harrisburg, PA 17105-2063 

May 2,2007 

Water Planning Office 

Mr. David Cottingham, Chief 

Marine Mammal and Sea Turtle Conservation Division 

Office of Protected Resources 

Department of Commerce 

National Oceanic and Atmospheric Administration 

National Marine Fisheries Service 

Silver Spring, MD 2091 0-3226 

Re: DEP File No. CZ7:FDP 

Dear Mr. Cottingharn: 

The Pennsylvania Coastal Resources Management (CRM) Program has reviewed information 

received in this office on March 9,2007, concerning the proposed project titled "Draft Programmatic 

Environmental Impact Statement for the Marine Mammal Health and Stranding Response 

Program". 

We concur with your determination that this federal action is consistent with Pennsylvania's 

CRM Program. 

Sincerely, 

Lawrence J. Toth 

Environmental Planner 

Coastal Resources Management Program 

An Equal Opportunity Employer Printed on Recycled Paper @ 
THIS PAGE INTENTIONALLY LEFT BLANK 
NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

 

This document provides the Rhode Island Coastal Resources Management Council (CRMC) with 

the National Marine Fisheries Service (NMFS) Consistency Determination under the Coastal 

Zone Management Act (CZMA) (16 U.S.C. 1451 et seq.) and 15 CFR Part 930, subpart C, for 

activities coordinated and conducted by the Marine Mammal Health and Stranding Response 

Program (MMHSRP).

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. Under Rhode Island’s Coastal Resources Management Act (Rhode Island General Law 

[RIGL], Title 46, Chapter 23, Section 1), the CRMC is directed to “exercise effectively its 

responsibilities in the coastal zone through the development and implementation of management 

programs to achieve wise use of the land and water resources of the coastal zone.” Under this 

authority, and pursuant to the CZMA, the CRMC is responsible for ensuring that Federal 

activities in the coastal zone are consistent to the maximum extent possible with the enforceable 

policies of the Rhode Island Coastal Resources Management Program (CRMP). The PEIS will 

assess the impacts of the proposed alternatives on coastal resources within the context of the 

policies enumerated in the Coastal Resource Management Act and the CRMP. 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division. 

However, at this time, no significant impacts on Rhode Island’s coastal resources are anticipated. 
In accordance with RIGL 46-23-6(B)(2), the preferred alternatives, with mitigation, do not, 

conflict with any resource management plan or program; make any area unsuitable for any uses 

or activities to which it is allocated by a resource management plan; or significantly damage the 

environment of the coastal region. 

Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 

consistent to the maximum extent practicable with the enforceable policies of the Rhode Island 

CRMP. The Rhode Island CRMC has 60 days (plus any appropriate extension under 15 CFR 

930.41(b)) from the receipt of this letter and accompanying information in which to concur with 

or object to the NMFS Consistency Determination. Concurrence will be presumed if the State’s 

response is not received by NMFS on the 60th day from receipt of this Determination. 

 
s STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS 

COASTAL RESOURCES MANAGEMENT COUNCIL 

Oliver H. Stedman Government Center 

4808 Tower Hill Road, Suite 3 

Wakefield, R.I. 02879- 1900 

(401) 783-3370 

FAX. (401) 783-3767 

March 14,2007 

Mr. David Cottingham 

Chief, Marine Mammal and Sea Turtle Conservation Division 

Office of Protected Resources 

National Marine Fisheries Service 

13 15 East-West Highway 

Silver Spring, MD 209 1 0 

RE: CRMC File No. 2007-03-037 

Dear Sirs: 

In accordance with Title 15 of the Code of Federal Regulations, Part 930, Subpart C 

(Consistency for Federal Activities) and review of plans entitled: 

Marine Mammal Health and Stranding Response Program programmatic Environmental 

Impact Statement, 

The Coastal Resources Management Council hereby concurs with the determination that 

the referenced project is consistent with the federally approved Rhode Island Coastal Resources 

Management Program and applicable regulations therein. 

Please contact this office at (401) 783-3370 should you have any questions. 

Sincerely, 
THIS PAGE INTENTIONALLY LEFT BLANK 
NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

This document provides the South Carolina Department of Health and Environmental Control, 

Office of Ocean and Coastal Resource Management (OCRM) with the National Marine Fisheries 

Service (NMFS) Consistency Determination under the Coastal Zone Management Act (CZMA) 

(16 U.S.C. 1451 et seq.) and 15 CFR Part 930, subpart C, for activities coordinated and conducted 

by the Marine Mammal Health and Stranding Response Program (MMHSRP).

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

 

2. Under South Carolina’s Coastal Zone Management Act (S.C. Code of Laws, Title 48, Chapter 

39, Section 80), the State Coastal Management Program “shall provide for consideration of 

whether a proposed activity of any applicant for a federal license or permit complies with the 

State’s coastal zone program and for the issuance of notice to any concerned federal agency as to 

whether the State concurs with or objects to the proposed activity.” The PEIS will assess the 

impacts of the proposed alternatives on coastal resources that are provided under South 

Carolina’s Coastal Zone Management Act. 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division. 

However, at this time, no significant impacts on South Carolina’s coastal resources are 

anticipated. The preferred alternatives, with mitigation, are consistent with the State Coastal 

Zone Management Act policies regarding barrier islands, dunes, wetlands, natural areas, marine 

and estuarine sanctuaries, and cultural resources. 
Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 

consistent to the maximum extent practicable with the enforceable policies of the South Carolina 

Coastal Management Program. The OCRM has 60 days (plus any appropriate extension under 15 

CFR 930.41(b)) from the receipt of this letter and accompanying information in which to concur 

with or object to the NMFS Consistency Determination. Concurrence will be presumed if the 

State’s response is not received by NMFS on the 60th day from receipt of this Determination. 
C. E,wI I Junter, Commissioner 

Pronwtingandprolecling the health of thepublic and Ihem~nronmcnzl. 

April 28,2007 

DAVID COTTINGHAM 

UNITED STATES DEPARTMENT OF COMMERCE 

NATIONAL MARINE FISHERIES SERVICE 

SILVER SPRING MD 209 1 0 1 

Re: Marine Mammal Health & Stranding 

CHARLESTON County 

Federal Consistency - 58030 

Dear Mr. Cottingham: 

The staff of the Office of Ocean and Coastal Resource Management (OCRM) certifies that the above 

referenced project is consistent with the S.C. Coastal Zone Management Program provided that (1) 

no freshwater wetlands are disturbed or altered and that (2) all necessary erosion and sediment 

control practices are maintained until the entire site is stabilized. This certification shall serve as the 

final approval for the referenced permit only, by OCRM. 

Sincerely, 

BARBARA NEALE 

Regulatory Programs Division 

S O U T H C A R O L I N A DEPARTMENT OF HEALTH AND ENVIRONMENTAL CONTROL 

Ocean and Coastal Resource Management 

Charleston Office. 1362 McMillan Avenue, Suite 400 Charleston, SC 29405 

Phone: 843-953-0200 . Fax: 843-953-020 1 . www.scdhec.gov 
THIS PAGE INTENTIONALLY LEFT BLANK 
NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

This document provides the Texas General Land Office, Coastal Resources Program with the 

with the National Marine Fisheries Service (NMFS) Consistency Determination under the Coastal 

Zone Management Act (CZMA) (16 U.S.C. 1451 et seq.) and 15 CFR part 930, subpart C, for 

activities coordinated and conducted by the Marine Mammal Health and Stranding Response 

Program (MMHSRP).

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. Under Texas’ Natural Resource Code, Section 33.053, the Texas Coastal Management 

Program (CMP) includes a procedure for “determining the consistency of a federal action or 

activity with the goals and policies of the coastal management program.” The PEIS will assess 

the impacts of the proposed alternatives on coastal resources in the context of the goals and 

policies detailed in the Texas Coastal Management Program Final EIS. These goals and policies 

are enforceable under Texas Administrative Code (TAC), Title 31, Chapter 501. 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division. 

However, at this time, no significant impacts on Texas’ coastal resources are anticipated. The 

preferred alternatives, with mitigation, are consistent with the policies enumerated in 31 TAC 

§501.20. 
Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 

consistent to the maximum extent practicable with the enforceable policies of the Texas Coastal 

Management Program. The Texas Coastal Management Program has 60 days (plus any 

appropriate extension under 15 CFR 930.41(b)) from the receipt of this letter and accompanying 

information in which to concur with or object to the NMFS Consistency Determination. 

Concurrence will be presumed if the State’s response is not received by NMFS on the 60th day 

from receipt of this Determination. 
NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

This document provides the Virginia Department of Environmental Quality, Office of 

Environmental Impact Review with the National Marine Fisheries Service (NMFS) Consistency 

Determination under the Coastal Zone Management Act (CZMA) (16 U.S.C. 1451 et seq.) and 15 

CFR Part 930, subpart C, for activities coordinated and conducted under the Marine Mammal 

Health and Stranding Response Program (MMHSRP). 

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. Under the Code of Virginia, Title 10, Chapter 1, Section 1183, the Department of 

Environmental Quality has the authority to “coordinate state reviews with federal agencies on 

environmental issues, such as environmental impact statements.” Under Executive Order ThirtyThree, this authority extends to ensuring that federal programs and activities are carried out in a 

manner that is consistent with the federally-approved Virginia Coastal Management Program. 

The PEIS will assess the impacts of the proposed alternatives on coastal resources. 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division. 

However, at this time, no significant impacts on Virginia’s coastal resources are anticipated. The 

preferred alternatives, with mitigation, are consistent with policies regarding wetlands, dunes, 

coastal lands, and historical sites. Based upon the preceding information, data and analysis, 

NMFS finds that the MMHSRP is consistent to the maximum extent practicable with the 

enforceable policies of the Virginia Coastal Resources Management Program. The Virginia 

Coastal Management Program has 60 days (plus any appropriate extension under 15 CFR 
930.41(b)) from the receipt of this letter and accompanying information in which to concur with 

or object to the NMFS Consistency Determination. Concurrence will be presumed if the State’s 

response is not received by NMFS on the 60th day from receipt of this Determination. 
L. Preston Bryant, Jr. 

Secretary of Natural Resources 

COMMON WEALTH of VIRGINIA^ 

DEPARTMENT OF ENVIRONMENTAL QUALITY 

Street address: 629 East Main Street, Richmond, Virginia 23219 

Mailing address: P.O. Box 1105, Richmond, Virginia 23218 

Fax (804) 698-4500 TDD (804) 698-4021 

www.deq.virginia.gov 

David K. Paylor 

Director 

May 1,2007 

Mr David Cottingham 

Chief, Marine Mammal and Sea Turtle Conservation Division 

Office of Protected Resources 

National Marine F~sher~es Serv~ce 

1 31 5 East-West H lg hway 

Room 13635 

S~lver Spring, Maryland 2091 0 

RE: Marine Mammal Health and Stranding Response Program, 

Federal Consistency Determination and Draft Programmatic 

Environmental Impact Statement 

DEQ-07-043F f :;;? 

Dear Mr. Cottingham: 

The Commonwealth of Virginia has completed its review of the abovelisted Draft Programmatic Environmental Impact Statement (Draft PEIS) and 

federal consistency determination. The Department of Environmental Quality 

("DEQ") is responsible for coordinating Virginia's review of federal environmental 

documents prepared pursuant to the National Environmental Policy Act ("NEPA) 

and responding to appropriate federal officials on behalf of the Commonwealth. 

DEQ is also responsible for coordinating Virginia's review of federal consistency 

determinations submitted pursuant to the Coastal Zone Management Act and 

providing the state's response to same. The following state agencies and 

regional planning district commission joined in this review: 

Department of Environmental Quality 

Department of Game and Inland Fisheries 

Department of Conservation and Recreation 

Marine Resources Commission 

Hampton Roads Planning District Commission. 

In addition, the Virginia Institute of Marine Science and the AccomackNorthampton Planning District Commission were invited to comment. 
Mr. David Cottingham 

Page 2 

Description of Action 

The National Marine Fisheries Service (NMFS) was charged by a 1992 

amendment to the Marine Mammal Protection Act of 1972 to develop a marine 

mammal health and stranding response program aimed at facilitating the 

exchange of data on the health of marine mammals in the wild, correlating that 

health with available data on environmental and other conditions, and 

coordinating effective responses to unusual mortality events. In pursuit of these 

goals, NMFS proposes a program of four components: 

a) lssuance of a Policies and Best Practices guidance document; 

b) lssuance of a new 5-year permit under the Endangered Species Act and 

the Marine Mammal Protection Act to the program, covering anticipated 

future activities including disentangling, monitoring, and import and export 

of tissue samples; 

c) Continuation of current operations, including response, rehabilitation, 

release, and research; and 

d) Continuation of the Prescott Grant program, which provides funding to 

standing network members (including, in Virginia, the Virginia Institute of 

Marine Science and the Virginia Aquarium and Marine Science Center). 

(Draft PEIS, pages ES-1 and ES-2, section ES.l.) 

The Draft PEIS considers a number of alternative ways to address each of 

t.he six topics addressed by the program. The topics are: 

Stranding agreements and response 

Carcass disposal 

Rehabilitation activities 

Release activities 

Disentanglement 

Bio-monitoring and research activities 

(Draft PEIS, pages ES-3 and ES-4; see also Chapter 2.) 

Federal consistency determinations for coastal states, including Virginia, 

appear within Appendix B, "Agency Coordination and Consultation" in Volume 2 

of the Draft PEIS. 

Environmental Impacts and Mitigation 

I. Waste Management. By assuming control of the carcass of a marine 

mammal, the marine mammal stranding teams may be subject to the 
Mr. David Cottingham 

Page 3 

requirement to properly manage the carcass under the Virginia Solid Waste 

Manasement Regulations. These require the disposal of animal remains at a 

permitted solid waste management facility. DEQ recognizes, however, that 

movement of large carcasses to a permitted waste facility would be difficult, 

expensive, and possibly more destructive to the coastal environment than burial 

in place. Moreover, leaving the carcass to naturally decompose would also have 

multiple negative effects. 

2. Wildlife Resources. The Department of Game and Inland Fisheries, as 

the Commonwealth's wildlife and freshwater fish management agency, exercises 

enforcement and regulatory jurisdiction over wildlife and freshwater fish, including 

state or federally listed endangered or threatened species, but excluding listed 

insects. The Department (hereinafter "DGIF") is a consulting agency under the 

U.S. Fish and Wildlife Coordination Act (16 U.S.C. sections 661 et ses.), and 

provides environmental analysis of projects or permit applications coordinated 

through the Department of Environmental Quality and several other state and 

federal agencies. DGIF determines likely impacts upon fish and wildlife 

resources and habitat, and recommends appropriate measures to avoid, reduce, 

or compensate for those impacts. 

According to the Department of Game and Inland Fisheries (DGIF), the 

preferred alternatives appear reasonable. 

(a) Rehabilitation Activities. The Draft PElS places considerable 

emphasis on rehabilitation activities. It should be noted that marine mammals 

are notoriously difficult to maintain in captivity; success in their treatment, 

rehabilitation, and release requires considerable staff and resources. Moreover, 

treating and releasing animals that are compromised, or otherwise genetically 

unfit to survive (e.g., a starving pinniped full of worms) without human 

intervention, may not be in the best interests of the population at large. NMFS7s 

program should include criteria that clearly identify high-priority species (such as 

threatened or endangered species, or species of high conservation concern) that 

quality for some measures of human intervention. The criteria should also 

address the sources of debilitation that are appropriate to treat (i.e., humaninduced versus natural). 

(b) Marine Mammal Carcass Disposal. The Draft EIS recommends the 

transport of all chemically euthanized carcasses off site (page 2-5, section 

2.1.2.2). The premise behind this recommendation (Draft EIS, page 2-4, section 

2.1.2.1) is valid, and in most cases the recommendation can be followed. 

However, in cases involving large whales or mass strandings, removal to off-site 

locations may not be feasible. Allowances should be made, therefore, for on-site 
Mr. David Cottingham 

Page 4 

disposal when it becomes logistically impossible to remove chemically 

euthanized animal carcasses from the beach. 

3. Regional Comments. The Hampton Roads Planning District 

Commission, which represents the Virginia localities south of Hampton Roads, 

indicates that the proposed action is generally consistent with local and regional 

plans and policies. 

Federal Consistency under the Coastal Zone Management Act 

Pursuant to the Coastal Zone Management Act of 1972, as amended, 

federal activities located inside or outside of Virginia's designated coastal 

management area that can have reasonably foreseeable effects on coastal 

resources or coastal uses must, to the maximum extent practicable, be 

implemented in a manner consistent with the Virginia Coastal Resources 

Management Program (VCP). The VCP consists of a network of programs 

administered by several agencies. The DEQ coordinates the review of federal 

consistency determinations with agencies administering the Enforceable and 

Advisory Policies of the VCP. 

DEQ published a public notice of this review from March 26, 2007 through 

April 19, 2007. No comments were received from the public. 

Based on the information submitted and the comments of reviewing 

agencies, we concur that the proposed program elements are consistent with the 

Virginia Coastal Resources Management Program, provided that NMFS complies 

with all applicable requirements, and that no effort is made to dispose of 

carcasses in wetlands (see item 3, below). 

I. Fisheries Management. The Department of Game and Inland Fisheries 

finds that implementation of the program is likely to have beneficial impacts on 

wildlife resources. The program will not adversely affect threatened, 

endangered, or critical wildlife resources under the Department's jurisdiction. 

The Department finds the program to be consistent with the fisheries 

management enforceable policy of the Virginia Coastal Resources Management 

Program. 

2. Subaqueous Lands Management. The Marine Resources Commission 

requires a permit for any activities that encroach upon, or over, or take materials 

from the beds of the bays, ocean, rivers, streams, and creeks which are the 

property of the Commonwealth. If any such activities are contemplated, 

application for and issuance of a permit from the Commission will ensure that the 
Mr. David Cottingham 

Page 5 

permitted activity is consistent with the subaqueous lands management 

enforceable policy of the Virginia Coastal Resources Management Program. 

3. Wetlands Management. As DEQ's Tidewater Office and its Virginia 

Water Protection Permit Program Office indicate, any carcass disposal activities 

involving excavation in wetlands would be regulated under state law. Because of 

the time frame of the wetland permitting process (120 days from a complete 

application to permit issuance), it is unrealistic to expect that such activity could 

be appropriately permitted. For this reason, any land-based carcass disposal 

should be undertaken outside of wetland areas. 

If wetland areas were to be proposed for use in this regard, a Virginia 

Water Protection Permit (VWPP) would be required for excavation or any other 

impacts in wetlands. VWPP regulations allow wetland impacts to be permitted 

only if the proposal is the least environmentally damaging practicable alternative. 

In this case, it appears that there may be alternatives to wetland disposal that are 

more practicable and less damaging to wetlands: 

disposal on-site at the beach; 

offshore disposal; or 

disposal at an approved solid waste facility 

For these reasons, it would be difficult to obtain a VWP permit for this activity. 

4. Coastal Lands Management. According to the Department of 

Conservation and Recreation's Division of Chesapeake Bay Local Assistance 

(Division), which administers the Chesapeake Bay Preservation Act (Virginia 

Code sections 10-1 -21 00 et seq.), addressing the stranding of marine mammals 

is assumed to be an emergency situation requiring temporary land disturbance. 

This particular activity is neither allowed nor disallowed in Chesapeake Bay 

Preservation Areas (Resource Protection Areas and Resource Management 

Areas). However, should it be required, any land-disturbing activity should be 

minimized, and access through the Chesapeake Bay Preservation Areas should 

be restricted to one point. Some explanation follows (BairdlEllis, 4130107). 

(a) Definitions. The Chesapeake Bay Preservation Act and the 

Chesapeake Bav Preservation Area Designation and Management Regulations 

implementing the Act (9 VAC 10-20-10 et seq.) set out a state and local 

government program defining two types of Chesapeake Bay Preservation Areas 

and setting out requirements for activities in each of them. The more restrictive 

designation, "Resource Protection Areas," is likely to apply to shorelines where 

stranding or proposed disposal might take place. Resource Protection Areas 

(RPAs), as defined in the Regulations (9 VAC 10-20-40) include the following: 
Mr. David Cottingham 

Page 6 

tidal wetlands; 

non-tidal wetlands connected by surface flow and contiguous to 

tidal wetlands or water bodies with perennial flow; 

tidalshoreqand 

a 100-foot buffer adjacent to and landward of the aforementioned 

features, and along both sides of any water body with perennial 

flow. 

(b) General Performance Criteria. Resource Management Areas (the 

less restrictive, locally defined designation) and Resource Protection Areas are 

subject to general performance criteria, which include the following (see 9 VAC 

1 0-20-1 20): 

minimizing land disturbance; 

preserving indigenous vegetation; 

minimizing impervious surfaces; 

controlling stormwater runoff quality; and 

developing Erosion and Sediment Control Plans for land 

disturbances greater than or equal to 2,500 square feet. 

Requlatow and Coordination Needs 

1. Subaqueous Lands Management. Any program activities affecting 

state-owned subaqueous lands may require a permit from the Marine Resources 

Commission. Questions on applicability and fulfillment of this requirement may 

be directed to the Commission (George Badger, telephone (757) 247-2200). 

2. Marine Mammal Consen/ation. NMFS is encouraged to consult with .the 

Department of Game and Inland Fisheries (Ruth Boettcher, telephone (757) 787- 

591 1) as it implements proposed management actions. 

3. Local Coordination. NMFS is encouraged to contact appropriate local 

authorities in implementing proposed management actions. 

Thank you for the opportunity to review this Draft PElS and federal 

consistency determination. If you have questions, please feel free to call 
Mr. David Cottingham 

Page 7 

me (telephone (804) 698-4325) or Charles Ellis of this Office (telephone (804) 

698-4488). 

Sincerely, 

Ellie L. Irons 

Program Manager 

Office of Environmental Impact Review 

Enclosures 

cc: Andrew K. Zadnik, DGlF 

Ruth Boettcher, DGlF 

Michelle R. Hollis, DEQ-TRO 

Michelle Henicheck, DEQ-VWP 

George H. Badger Ill, MRC 

David L. O'Brien, VlMS 

Alice R. T. Baird, DCR-DCBLA 

Arthur L. Collins, Hampton Roads PDC 

Paul F. Berge, Accomack-Northampton PDC 
THIS PAGE INTENTIONALLY LEFT BLANK 
From: 

Sent: 

To: 

Cc: 

Subject: 

Zadnik, Andrew (DGIF) 

Thursday, March 22, 2007 257 PM 

Ellis,Charles; Ruth Boettcher 

ProjectReview (E-mail); ProjectReview@dgif.virginia.gov 

07-043F-ESS 21907-Marine Mammal Health and Stranding ResponseProgram 

This project involves activities associated with the National Marine Fisheries Service's 

Marine Mammal Health and Stranding Response Program. The proposed actions include: 

1. Issuance of the Policies and Best Practices for Marine Mammal Stranding Response, 

Rehabilitation, and Release as final guidance. 

2. Issuance of a new Endangered Species Act (ESA)/MMPA permit to the MMHSRP. The new 

permit would include current and future response activities for endangered species, 

disentanglement activities, biomonitoring projects, and import and export of marine mammal 

tissue samples. 

3. Continuation of current MMHSRP operations, including response, rehabilitation, release, 

and research activities, with renewal and authorization of Stranding Agreements (SAs) and 

Scientific Research Authorizations and other NMFS activities. 

4. Continuation of the Prescott Grant Program, which provides funding to stranding network 

members. The two network members in Virginia are the Virginia Aquarium and Marine Science 

Center and the Virginia Institute of Marine Science, College of William and Mary. 

We do not anticipate a significant adverse impact upon threatened, endangered, or critical 

wildlife resources under our jurisdiction to occur due to this project. Implementation of 

the preferred alternatives should result in overall beneficial impacts upon wildlife 

resources. To assist in implementing the proposed actions, we recommend that the NMFS 

coordinate with the primary VDGIF biologist responsible for marine mammal conservation, 

Ruth Boettcher (757-787-5911) . 

We find this project consistent with the Fisheries Section of the Virginia Coastal 

Resources Management Program. 

Thank you, 

Andrew Zadnik 

Ruth, 

If you have any questions or comments about this, please let me and/or Charlie know by 

April 19. NMFS is interested in any comments we might have regarding the sorts of 

activities in response to stranded marine mammals or disease outbreaks should be conducted 

nationwide, how the national stranding network should be organized at the local, state, 

regional, ecosystem, and national levels, and what the minimum qualifications should be 

for an individual or group to become a Stranding Agreement holder. 

Sorry I went ahead and sent comments to DEQ, but I will be going on 2 weeks of paternity 

leave starting any day now, and I want to make sure our comments get to DEQ. 

Thanks 

Andy 

Andrew K. Zadnik 

Environmental Services Section Biologist 

Department of Game and Inland Fisheries 

4010 West Broad Street 

Richmond, VA 23230 
Comments on NMFS Marine mammal Health and Stranding Response Program EIS 

Ruth Boettcher, VDGIF 

41 16/07 

Overall, the preferred alternatives outlined in the document are reasonable and prudent and I 

agree with all of them in the context of this EIS. However, I do have some concern over the 

considerable emphasis that is place on rehabilitation activities. Marine mammals are notoriously 

difficult to maintain in captivity and require considerable staff and resources to successfully 

treat, rehabilitate and release. Moreover, treating and releasing animals that are compromised or 

otherwise genetically unfit to survive (e.g., a starving pinniped full of worms) without human 

intervention, may not be in the best interest of the population at large. The plan should include 

criteria that clearly identify high priority species (e.g., TIE species or species of high 

conservation concern) that qualify for some measure of human intervention and the sources of 

debilitation which are appropriate to treat (e.g., human-induced versus natural). 

I also have a minor concern regarding the preferred alternative under Marine Mammal Carcass 

Disposal (2.1.2.2) which recommends the transport of all chemically euthanized carcasses off 

site. The premise behind this recommendation is valid and in most cases can be followed. 

However, cases involving large whales or mass strandings, this may not be feasible. As such, 

allowances should be made for on site disposal when it becomes logistically impossible to 

remove chemically euthanized animals carcasses from the beach. 
Page 1 of 1 

From: Henicheck,Michelle 

Sent: Friday, April 13, 2007 4:06 PM 

To: Ellis,Charles 

Cc: Davis,David 

Subject: Marine Mammal Health and Stranding Response Program 

Charlie, 

I have reviewed the documents provided to me today regarding the above referenced program. Central Office concurs 

with the Tidewater comments regarding disposal of the dead marine life. DEQ would require a VWP permit for 

excavation in, or other impacts to wetlands to dispose of marine life. VWPP Program regulations allow wetland impacts 

to be permitted only if the proposal is the least environmentally damaging, practicable alternative. It appears that other, 

more practicable alternatives may exist that would not impact wetlands, such as disposal on-site at the beach, off-shore 

disposal, or disposal at an approved solid waste facility, therefore, it may be extremely difficult to obtain a VWP permit. 

In addition, an individual VWP permit has a 120-day processing time and would not meet the time constraints that appear 

to be needed for disposal of a decomposing carcass. 

Michelle Henicheck, PWS 

Dept. of Environmental Quality 

Environmental Specialist I1 

Phone: 804-698-4007 

Fax: 804-698-4347 

mmhenicheck@deq.virginia.~ov 

*NEW mailing address: 

P.O. Box 1105 

Richmond, VA 23218 
DEPARTMENT OF ENVIRONMENTAL QUALITY 

TIDEWATER REGIONAL OFFICE 

ENVIRONMENTAL IMPACT REVIEW COMMENTS 

April 4,2007 

PROJECT NUMBER: 07-043F 

PROJECT TITLE: Marine Mammal Health and Stranding Response Program 

As Requested, TRO staff has reviewed the supplied information and has the following 

comments: 

Petroleum Storage Tank Cleanups: 

No objections or concerns. 

Petroleum Storage Tank Compliance/Inspections: 

No objections or concerns. 

Virginia Water Protection Permit Program (VWPP): 

We have reviewed this document from our programmatic perspective and note that the location and 

methods of disposal will be based on the facts surrounding unpredictable individual stranding events. 

Any carcass disposal activities that would involve excavation in wetlands would be regulated under 

state law. Given the time constraints associated with the permit process (120 days from a complete 

application), it is unrealistic to expect that such activity could be appropriately permitted. As such, 

any land based carcass disposal should be undertaken outside of wetland areas. 

Air Permit Program : 

No comments. 

Water Permit Program : 

,The TRO Water Permit Section has no comment on the document content as there is no activity 

described here that requires a water permit or is impacted by DEQ water pollution regulations to the 

best of my knowledge. However, it may be important to note that in general this project extends 

beyond the Tidewater region and may best be reviewed on a programmatic basis by personnel within 

the Central Office. 

Waste Permit Program : 

By assuming control of the carcass, the marine mammal stranding teams may be subject to the 

requirement to properly manage the carcass in accordance with the Virginia Solid Waste 

Management Regulations (VSWMR). Currently, the VSWMR requires the disposal of animal 

remains at a permitted solid waste management facility. However, it is realized that the movement of 

the large carcasses to a permitted facility would be difficult, expensive, and possibly more destructive 

to the coastal environment than burial in place and that leaving the carcass to naturally decompose 

would also have multiple negative effects. Because the proposal extends beyond the boundaries of 

the Tidewater Region and a possible variance may be required to continue to bury the carcasses on 

site it is recommended further discussions be conducted with DEQ staff at both the region and central 

office concerning the management and disposal of the carcasses. 
DEPARTMENT OF ENVIRONMENTAL QUALITY 

TIDEWATER REGIONAL OFFICE 

ENVIRONMENTAL IMPACT REVIEW COMMENTS 

-- - 

April 4,2007 

PROJECT NUMBER: 07-043F 

PROJECT TITLE: Marine Mammal Health and Stranding Response Program 

The staff from the Tidewater Regional Office thanks you for the opportunity to provide 

comments. 

Sincerely, 

Michelle R. Hollis 

Environmental Specialist 

5636 Southern Blvd. 

VA Beach, VA 23462 

(757) 5 18-2 146 

(757) 5 18-2009 Fax 

rnrhollis@deq.virginia.gov 
03/23/07 FRI 14:12 FAX 757 414 0559 DEQ VMRC E SHORE 

L. Pnston Bryant, Jr. 

Sccrcw of Naml Resources 

COMMONWEALTH of VIRGINIA 

Marine Resources Commission 

2600 Washington A vefiue 

ThirdFloor . 

Newport new.^. Virgi?tia 23607 

Stcvcn Ci. Bowman 

Comrnissioncr 

Mr. Charles H. Ellis Ill 

C/O Department. Of Environmental Quality 

Office of the Environrnenta.1 Impact Review 

629 East Main Street, Sixth Floor 

Richmond, Viginia 232 19 

Re: 07-043F, "Marine Mammal Health Progarn" 

Dear Mr. Ellis: 

You have inquired regarding the permitting requirements for Developing the Marine 

Mammal Heallh B ,Clanding Kesporue Program. The goal is to promote sound stewardship and 

improve the effectiveness of the National System. 

The Marine Resources Commission requires a permit for any activities that encroach upon 

or over, or take use of materials from the beds of the bays, ocean, rivers and streams, or creeks, 

which are the property of the Commonwealth. 

If'I may be of further assistance, please do not hesitate to contact me at (757) 414-0710. 

eorge IL Badger, Ill 

An Agetag uf the Natural Resnurces Secretariat 

Web Address: www.nuc.virrrinia.eov 

Tnl-LA-,\ /7~7\ 7A7 ?~nn 1'7c-n 14-1 qq1-19 xrrrnn T-r --.. L-- ..-A ,r .---------. II-AI:-- I onn err ~rrr ~7-n 
CHESAPEAKE 

Rebecca C.W. Adams, Council Member 

Armr Dwarkanath, Deputy City Manager 

Cliflon E. Hayes. Council Member 

Anne F. Odell. Acting City Manager 

Ella P. Ward. Council Member 

FRANKLIN 

Joseph J S~tslow~cz, Counc~l Member 

Rowland L Taylor. Cdy Manager 

GLOUCESTER COUNTY 

John J. Adam, Sr.. Board Member 

Wllllan-6 H. Whltley. County Administrator 

HAMPTON 

Randall A Gilllland. V~ce Mayor 

Ross A Kearney. I!, Mayor 

Jesse T Wallace. Jr . Cdy Manager 

ISLE OF WIGHT COUNTY 

W. Douglas Caskey, County Administrator 

Stan D. Clark. Vlce Chairrmn 

JAMES CITY COUNTY 

Bruce C Goodson, Charman 

Sanford B Wanner, County Admvlrstrator 

NEWPORT NEWS 

Charles C. Allen. V~ce Mayor 

Joe S. Frank. Mayor 

Randy W. Hlldebrandt, Cdy Manager 

NORFOLK 

Anthony L Burfoot. Vrce Mayor 

Paul D Fralrn, Mayor 

Dr Theresa W Whlbley. Counctl Member 

Reglna V K W~lllam. Cdy Manager 

Barclay C Wlnn. Cound Member 

POQUOSON 

:harles W. Burgess. Jr.. City Manager 

Gordon C. Helsel. Jr., Mayor 

PORTSMOUTH 

Jams B Oliver. Jr , Cdy Manager 

Douglas L Smlh. Cound Member 

SOUTHAMPTON COUNTY 

Anlta T Felts, Board Member 

Mlchael W Johnson. County Admm~strator 

SUFFOLK 

Linda T Johnson. Mayor 

James G. Vacalls. Cdy Manager 

SURRY COUNTY 

-yrone W. Franklin. County Administrator 

Judy S. Lyttle. Board Member 

VIRGINIA BEACH 

Harry E. D~ezel, Council Member 

Robert M. Dyer, Council Member 

Barbara M. Henley. Council Member 

Louis R. Jones, Vice Mayor 

Meyera E. Oberndorf, Mayor 

James K. Spore, City Manager 

John E. Uhrin, Council Member 

WILLIAMSBURG 

Jackson C. Tuttle. 11. Cdy Manager 

Jeanne Ze~dler. Mayor 

YORK COUNTY 

Jams 0 McReynolds. County Admnrstrator 

Thms G. Shepperd. Jr . Board Member 

PAUL 0. FRAIM, CHAIRMAN BRUCE C. GOODSON, VICE CHAIRMAN. JAMES o MCR~~YNOLDS, TREASURER 

ARTH* L. COLLINS. EXECUTIVE q(*ECTORISECRETARY 

RECEIVED 

April 19, 2007 

Mr. Charles H. Ellis Ill 

Department of Environmental Quality 

Office of Environmental Impact Review 

629 West Main Street, Sixth Floor 

Ric,"lmond, VA 2321 9 

Re: Marine Mammal Health and Stranding Response Program 

#07-043F (ENV:GEN) 

Dear Mr. Ellis: 

Pursuant to your request of March 14, 2007, the staff of the Hampton 

Roads Planning District Commission has reviewed the Draft 

Programmatic Environmental Impact Statement and Consistency 

Determination for the Marine Mammal Health and Stranding Response 

Program. 

Based on this review, the proposal is generally consistent with local and 

regional plans and policies. 

We appreciate the opportunity to review this project. If you have any 

questions, please do not hesitate to call. 

Arthur L. ~ollind - 

Executive Dire , orlsecretary 

HEADQUARTERS. THE REGIONAL BUILDING. 723 WOODLAKE DRIVE. CHESAPEAKE. VlRGl (A 23320. (757) 420-8300 

PENINSULA OFFICE. 2101 EXECUTIVE DRIVE. SUITE C HAMPTON. VIRGl$A 23666 . (757) 262m94 
THIS PAGE INTENTIONALLY LEFT BLANK 
NATIONAL MARINE FISHERIES SERVICE 

COASTAL ZONE MANAGEMENT ACT 

CONSISTENCY DETERMINATION 

 

This document provides the Washington Department of Ecology, Coastal Management Program 

with the National Marine Fisheries Service (NMFS) Consistency Determination under the Coastal 

Zone Management Act (CZMA) (16 U.S.C. 1451 et seq.) and 15 CFR Part 930, subpart C, for 

activities coordinated and conducted by the Marine Mammal Health and Stranding Response 

Program (MMHSRP). 

Necessary Data and Information: 

1. NMFS is announcing the availability of a draft Programmatic Environmental Impact 

Statement (PEIS) for the MMHSRP. Some activities of the MMHSRP are conducted under a 

permit issued under the Marine Mammal Protection Act (MMPA) (16 U.S.C. 1361-1421) and 

Section 10(a)(1)(A) of the Endangered Species Act (ESA) (16 U.S.C. 1531-1544) by the Permits, 

Conservation, and Education Division of the NMFS Office of Protected Resources. The current 

ESA/MMPA permit expires on June 30, 2007. A National Environmental Policy Act (NEPA) 

analysis of the current and future activities covered under the permit must be completed prior to 

the issuance of a new permit. The potential impacts of the permitted activities as well as the dayto-day operations of the MMHSRP are analyzed in the draft PEIS. Day-to-day operations include 

the coordination and oversight of the National Marine Mammal Stranding and Disentanglement 

Networks, the National Marine Mammal Tissue Bank, the Working Group on Unusual Marine 

Mammal Mortality Events, and the John H. Prescott Marine Mammal Rescue Assistance Grant 

Program. 

 

NMFS has also developed several policy documents that are collectively named the Policies and 

Best Practices for Marine Mammal Stranding Response, Rehabilitation and Release. These 

documents are currently issued on an interim basis, and the MMHSRP is proposing to issue them 

as final guidance after the NEPA analysis is concluded. The PEIS is intended to satisfy the 

requirements of NEPA and implementing regulations for all pertinent agency actions. 

2. Under Washington Administrative Code, Title 173, Chapter 27, Section 060, “Direct federal 

actions and projects (within the coastal counties) shall be consistent to the maximum extent 

practicable with the approved Washington state coastal zone management program.” The PEIS 

will assess the impacts of the proposed alternatives on coastal resources in the context of the 

Washington Coastal Program’s enforceable policies, including the Shoreline Management Act 

(Chapter 90.58 Revised Code of Washington [RCW]) and Ocean Resources Management Act 

(Chapter 43.143 RCW) 

3. Informal consultation has been initiated with NMFS Office of Protected Resources and the 

U.S. Fish and Wildlife Service to explore potential impacts to species protected under the ESA 

and the MMPA. A permit application for the MMHSRP activities involving ESA and MMPA 

species is currently being evaluated by the NMFS Office of Protected Resources Permits, 

Conservation and Education Division. 
However, at this time, no significant impacts on Washington’s coastal resources are anticipated. 

The preferred alternatives, with mitigation, are consistent with the Shoreline Management Act, 

the Ocean Resources Management Act, and the State Environmental Policy Act (Chapter 43.21C 

RCW). 

Based upon the preceding information, data and analysis, NMFS finds that the MMHSRP is 

consistent to the maximum extent practicable with the enforceable policies of the Washington 

Coastal Management Program. The Washington Coastal Management Program has 60 days (plus 

any appropriate extension under 15 CFR 930.41(b)) from the receipt of this letter and 

accompanying information in which to concur with or object to the NMFS Consistency 

Determination. Concurrence will be presumed if the State’s response is not received by NMFS 

on the 60th day from receipt of this Determination. 
Connecticut Commission on Culture & Tourism 

March 16,2007 

Historic Preservation 

& Museum Division 

59 South Prospect Street 

Hartford, Connecticut 

061 06 

(v) 860.566.3005 

(f) 860.566.5078 

Mr. David Cottingham 

Marine Mammal and Sea Turtle Conservation Division 

Office of Protected Resources, National Marine Fisheries Service 

National Oceanic and Atmospheric Administration 

13 15 East-West Highway 

Silver Spring, MD 209 10 

Subject: Marine Mammal Health and Stranding Response Program 

Dear Mr. Cottingham: 

The State Historic Preservation Office has reviewed the Draft Programmatic 

Environmental Impact Statement for the Marine Mammal Health and Strading 

Response Program prepared by the National Oceanic and Atmospheric 

Administration, National Marine Fisheries Service, Office of Protected 

Resources. This office expects that the proposed actions will have no adverse 

effect on Connecticut's coastal and maritime heritage. This comment is 

conditional upon our understanding that the National Oceanic and Atmospheric 

Administration shall consult with our professional staff with respect to actual field 

implementation of appropriate case-by-case actions. 

This office appreciates the opportunity to have reviewed and commented upon the 

proposed undertaking. 

This comment is provided in accordance with the National Historic Preservation 

Act and the Connecticut Environmental Policy Act. 

For further information, please contact Dr. David A. Poirier, Staff Archaeologist. 

Sincerely, 

\KS~GI~ Senich 

Deputy State Historic Preservation Officer 

An Affirmative Action 

Equal Opportunity Employer 
THIS PAGE INTENTIONALLY LEFT BLANK 
FLORIDA DEPARTMENT OF STATE 

Kurt S. Browning 

Secretary of State 

DMSION OF HISTORICAL RESOURCES 

Mr. David Cottingham 

National Marine Fisheries Service 

National Oceanic and Atmospheric Administration 

13 15 East-West Highway 

Silver Spring, MD 20910 

May 4,2007 

RE: DHR Project File No: 2007-2045fReceived by DHR: March 12,2007 

National Oceanic and Atmospheric Administration (NOAA) 

DraR Programmatic Environmental Impact Statement for the Marine Mammal Health and 

Stranding Response Program 

All Florida 

Dear Mr. Cottingham: 

This office received and reviewed the above referenced Environmental Impact Statement in 

accordance with Section 106 of the National Historic Preservation Act of 1966, as amended and 

36 CFR Part 800: Protection of Historic Properties and the National Environmental Policy Act 

of 1969, as amended. The State Historic Preservation Officer is to advise Federal agencies as 

they identify historic properties (listed or eligible for listing in the National Register of Historic 

Places), assess effects upon them, and consider alternatives to avoid or minimize adverse effects. 

This submission was well designed. Based on the information provided, this office concurs with 

NOAA that the above referenced federal plan (or action) will have only a minor adverse impact 

on historic properties. As a result, NOAA needs to make contingency plans in the case of 

fortuitous finds or unexpected discoveries during ground disturbing activities on the particular 

property. If prehistoric or historic artifacts, such as pottery or ceramics, projectile points, dugout 

canoes, metal implements, historic building materials, or any other physical remains that could 

be associated with early Native American, early European, or American settlement are 

encountered at any time within the project site area, the applicant shall contact the Florida 

Department of State, Division of Historical Resources, Review and Compliance Section at (850) 

245-6333 once rescue or carcass removal activities are finished. Non emergency project 

activities shall not resume without verbal andlor written authorization. In the event that 

unmarked human remains are encountered during permitted activities, all work shall stop 

immediately and the proper authorities notified in accordance with Section 872.05, Florida 

Statutes. 

500 S. Bronough Street Tallahassee, FL 32399-0250 http://www.flheritage.com 

0 Director's Office 0 Archaeological Research El Historic Preservation 0 Historical Museums 

(850) 245-6300 FAX: 245-6436 (850) 245-6444 FAX: 245-6452 (850) 245-6333 FAX: 245-6437 (850) 245-6400 FAX: 245-6433 

Southeast Regional Office 0 Northeast Regional Office 0 Central Florida Regional Office 

(561) 416-2115 FAX: 416-2149 (904) 825-5045 FAX: 825-5044 (813) 272-3843 FAX: 272-2340 
Mr. Cottingham 

May 4,2007 

Page 2 

If you have any questions, please contact James Toner, Historic Sites Specialist, by 

electronic mail at jetonen@dos.state.fl.us, or at 850-245-6333. 

Sincerely, 

XfJJ rGAL 

Frederick P. Gaske, Director, and 

State Historic Preservation Officer 
April 3, 2007 

Mr. David Cottingham, Chief 

Marine Mammal and Sea Turtle Conservation Division 

Office of Protected Resources 

National Marine Fisheries Service 

National Oceanic 

and Atmospheric Administration 

3 1 15 East-West Highway 

Silver Spring, Maryland 209 1 0 

SHPO: 03-19-07-03 NATIONAL OCEANIC AND ATMOSPHERIC 

ADMINISTRATION DRAFT PROGRAMMATIC ENVIRONMENTAL 

IMPACT STATEMENT FOR THE MARINE MAMMAL HEALTH AND 

STRANDING RESPONSE PROGRAM, ISLANDWIDE, PUERTO RlCO 

Dear Mr. Cottingham: 

Our Office received correspondence on March1 9, 2007 regarding the 

above referenced project. We have reviewed the Draft Programmatic 

Environmental Impact Statement for the Marine Mammal Health and 

Stranding Response Program. We concur with the coordination 

procedures presented in chapter 5.4 of the Draft EIS. 

If you have any questions, please contact Miguel Bonini at (787) 721 - 

3737 or mbonini@prshpo.gobierno.pr. 

Sincerely, 

State Historic Preservation Officer 

P.O. Box 9066581 

San Juan, PR 00906-6581 

mTel. (787) 721-3737 

 ax. (787) 722-3622 

www.oech.gobierno.pr 
THIS PAGE INTENTIONALLY LEFT BLANK 
APPENDIX C 

POLICIES AND BEST PRACTICES FOR MARINE MAMMAL 

STRANDING RESPONSE, REHABILITATION, AND RELEASE

NATIONAL TEMPLATE

MARINE MAMMAL STRANDING 

AGREEMENT BETWEEN 

NATIONAL MARINE FISHERIES SERVICE OF THE 

NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION 

DEPARTMENT OF COMMERCE 

AND 

[Stranding Network Organization] 

 Prepared by Janet E. Whaley, DVM February 2009 

Office of Protected Resources 

1315 East-West Highway 

Silver Spring, MD 20910 

Shaded denotes reserved text at the discretion of the NMFS Regional Administrator 

Articles III, IV, V, and VI are reserved and issued at the discretion of the NMFS Regional 

Administrator. 
 

2

Table of Contents 

ARTICLE I – General Provisions ............................................................................................... 3

ARTICLE II- Purpose and General Responsibilities................................................................ 5

ARTICLE III- Dead Animal Response..................................................................................... 11

ARTICLE IV- Live Animal Response: First Response........................................................... 14

ARTICLE V- Live Animal Response: Rehabilitation and Final Disposition ....................... 19

ARTICLE VI- Participant’s Authorized Personnel ................................................................ 25

ARTICLE VII- Rights of States and Local Governments ...................................................... 27

ARTICLE VIII- Effective Dates, Renewal, and Application Procedures ............................. 28

ARTICLE IX- Review, Modification, and Termination ......................................................... 30
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article I 

 

3

ARTICLE I 

General Provisions

A. Authority 

1. This Marine Mammal Stranding Agreement (hereinafter Agreement) is entered into 

between the Department of Commerce, National Oceanic and Atmospheric 

Administration (NOAA), National Marine Fisheries Service (NMFS)[insert Regional 

Office], and the Stranding Network Participant [insert Stranding Network Organization] 

(Participant), under the authority of section 112(c) and section 403 of the Marine 

Mammal Protection Act of 1972 (MMPA), as amended. This Agreement supersedes all 

pre-existing Stranding Agreements between these parties. An organizational 

representative with signatory authority (e.g. Executive Director, President, CEO) 

must sign this Agreement on behalf of the Stranding Network Organization. 

2. NMFS has been delegated authority by the Department of Commerce to administer the 

MMPA. To assist in the implementation and administration of the MMPA, the Stranding 

Network has been established to respond to stranded marine mammals within NMFS’ 

[insert Region] of the United States. The [insert Region] consists of the following coastal 

states and territories: [List states/territories]. 

B. Scope 

1. Under the MMPA, NMFS is responsible for mammals of the Order Cetacea and the 

Order Pinnipedia other than walruses (hereinafter marine mammals). 

2. The geographic response area assigned to Participant consists of the following: [(list 

response area including primary and secondary geographic response areas as necessary)]. 

 The Participant may assist in stranding response within the Region outside of their 

assigned response area, if requested by NMFS or by another Participant. Outside the 

[insert Region], the Participant may assist with stranding response upon request from the 

appropriate regional NMFS Regional Stranding Coordinator(s). 

C. Limitations 

1. This Agreement creates an authorization for the Participant to take marine mammals, 

which would be otherwise prohibited by the MMPA. This taking authorization only 

applies to the Participant and its authorized personnel (see Article VI) for activities that 

are consistent with this Agreement. 

2. In particular, this Agreement does not authorize: 

a. The taking of any marine mammal species listed as endangered or threatened 

under the Endangered Species Act of 1973 (ESA), as amended. Authorization to 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article I 

 

4

take ESA listed species is provided under an MMPA/ESA Permit No. 932-1489-

09, as amended, issued to the NMFS National Marine Mammal Health and 

Stranding Response Program Coordinator and requires authorization and direction 

from the NMFS Regional Stranding Coordinator in the event of a stranding 

involving a threatened or endangered marine mammal. 

 b. The sale or offer of sale of any marine mammal or marine mammal parts 

 including cells, gametes, or cell cultures. 

D. Definitions 

All terms used in the Agreement shall be interpreted to have the meaning specified in the 

MMPA section 3 and section 409 and NMFS implementing regulations 50 CFR 216.3 

unless the context or specific language requires otherwise. For ease of reference, those 

definitions, as well as additional terms and definitions for this Agreement, are provided 

in Attachment A. 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article II 

 

5

ARTICLE II 

Purpose and General Responsibilities

A. Purpose of Agreement. NMFS and the Participant enter into this Agreement for the 

following purposes: 

1. To provide for rapid response and investigation of stranded marine mammals [insert 

taxa] within the [insert Region] in accordance with the purposes and policies of the 

MMPA. 

2. To implement Title IV (Marine Mammal Health and Stranding Response Program) of the 

MMPA: 

a. to facilitate the collection and dissemination of reference data on the health of 

marine mammals and health trends of marine mammal populations in the wild; 

b. to correlate the health of marine mammals and marine mammal populations in the 

wild with available data on physical, chemical, and biological environmental 

parameters; and 

c. to detect and coordinate effective responses to Marine Mammal Unusual 

Mortality Events (UMEs). 

3. To specify the activities during which the Participant may take stranded marine mammals 

[insert taxa] or marine mammal parts for the primary purpose of ensuring the appropriate 

response, [rehabilitation], disposition, and utilization of stranded marine mammals or 

marine mammal parts under MMPA sections 109(h), 112(c), and 403 and the Agreement. 

4. To define the nature and extent of services that the Participant will provide NMFS under 

this Agreement and NMFS’ responsibilities to the Participant. 

5. To specify the requirements for the preparation and maintenance and reporting of records 

containing scientific data obtained from dead and live stranded marine mammals or parts 

from dead stranded marine mammals. 

6. To provide for the timely exchange of information for use by both parties and other 

network members in furthering the objectives of the MMPA under this Agreement. 

 

B. Joint Responsibilities 

NMFS and the Participant will work cooperatively to: 

1. Implement Title IV of the MMPA; 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article II 

 

6

2. Effectively respond to and investigate the causes and impacts of UMEs; 

3. Collect the appropriate data for determination of serious injuries and mortalities due to 

human interactions; 

4. Collect reference data on marine mammal health and diseases; 

5. Collect data on the frequency and causes of strandings; and 

6. Interpret findings and identify health trends and diseases of concern to include emerging, 

reportable, and zoonotic diseases. 

C. NMFS Responsibilities 

NMFS Shall: 

1. Provide the Participant with notice of any changes to laws, regulations, policies and/or 

guidelines applicable to or promulgated by NMFS that may apply to the Participant’s 

activities. This includes criteria for issuance, renewal and termination of stranding 

agreements. Notwithstanding this provision, it is the responsibility of the Participant to 

comply with all laws, regulations, policies and/or guidelines that apply to the 

Participant’s activities. 

2. Conduct periodic (Reserved annual) compliance reviews of Stranding Agreements as 

stated in Article IX. 

3. Provide guidance and assistance regarding investigation of marine mammal unusual 

mortality events including financial and physical resources (example: NOAA laboratory 

assistance) and financial resources when available and authorized (in accordance with 

section 405 of the MMPA – UME National Contingency Fund) and in coordination with 

the Working Group on Marine Mammal Unusual Mortality Events. 

4. Alert the Participant when NMFS has been notified that there are diseases of concern that 

are emerging, reportable, and/or zoonotic within the [insert Region]. 

5. Pursuant to criteria established under the MMPA section 407, provide access to the 

National Marine Mammal Health and Stranding Response Program Database, as 

developed, and access to marine mammal tissues in the National Marine Mammal Tissue 

Bank following NMFS data and tissue access procedures and policies. 

6. As needed and as resources are available, provide specialized marine mammal stranding 

response and investigation training on a local, regional or national basis. 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article II 

 

7

7. Pursuant to MMPA section 402, collect and update periodically and make available 

to stranding network participants and other qualified scientists, existing information on: 

a. procedures and practices for rescuing and rehabilitating stranded marine 

mammals; 

 b. species by species criteria used by the stranding network participants, for 

determining at what point a marine mammal undergoing rescue and rehabilitation 

is returnable to the wild based on its ability to survive in the wild and risk to the 

wild population of marine mammals; 

 c. procedures and practices for collecting, preserving, labeling, and transporting 

marine mammal tissues for physical, chemical, and biological analyses; 

 d. relevant scientific literature on marine mammal health, disease, and 

rehabilitation; 

 e. compilation and analyses of strandings by region to monitor species, numbers, 

conditions, and causes of illness and death in stranded marine mammals; and 

 

 f. other life history and reference level data, including marine mammal tissue 

analyses that would allow comparison of the causes of illness and death in 

stranded marine mammals with physical, chemical, and biological environmental 

parameters. 

8. Identify a Stranding Coordinator who will serve as the Participant’s primary point of 

contact for notification, coordination, reporting, and response [and rehabilitation] 

activities as specified throughout this Agreement. The NMFS Regional Administrator 

will serve as the Participant’s primary point of contact for administration of the 

Agreement, as well as dispositions and other management activities as specified 

throughout the Agreement. The NMFS Regional Administrator’s designated point of 

contact for this Agreement is the NMFS Stranding Coordinator; [Regional stranding 

coordinator or administrator, Regional Office, Protected Resources Division] (see 

Attachment B for contact information). 

9. In certain circumstances such as large scale events (e.g. mass stranding, unusual 

mortality events, live right whale stranding), NMFS may establish a formal Incident 

Command System (ICS) for response, including the identification of an Incident 

Commander. Events such as oil spills, NMFS will follow direction from United States 

Coast Guard (USCG). Opportunities for ICS training can be accessed through the 

Federal Emergency Management Agency (see 

http://www.training.fema.gov/EMIWeb/IS/is100.asp), USCG, or NMFS. If necessary, 

guidance will be provided by NMFS on a case-by-case basis. 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article II 

 

8

10. Relay reports of stranded marine mammals (live or dead) within the Participant’s 

geographic range to the Participant and inquire whether the Participant has the capability 

to respond. If the Participant cannot respond, the Stranding Coordinator may make 

requests to other regional Stranding Participants to respond. 

 

11. Coordinate regional activities to maximize geographic coverage while facilitating 

appropriate division of responsibilities among regional Participants according to 

institutional abilities and authorities. 

12. Respond to the Participant’s completed requests for authorizations such as requests for 

parts authorizations, parts transfers, and release determinations. 

 

13. Provide information regarding availability of Prescott Grants and any other relevant 

NMFS funding opportunities. 

 14. [Reserved {For emergency stranding events (live or dead), provide and maintain a 24-

hour stranding hotline number: ### ###-####. NMFS shall also provide and maintain a 

backup stranding pager number:### ###-####.}] 

D. Participant Responsibilities 

The Participant shall: 

1. Comply with laws, regulations, policies and/or guidelines applicable to or promulgated 

by NMFS that apply to activities under this Agreement; or any Federal, state or 

municipal laws that pertain to stranding network operations (e.g., municipal water 

management laws). 

2. Cooperate with other members of the [insert Region] Stranding Network and the 

National Marine Mammal Stranding Program as well as Federal, state, and local officials 

and employees in matters supporting the purposes of this Agreement. 

3. Be subject to the direction of a designated employee (e.g., NMFS Marine Mammal 

Stranding Coordinator or NMFS Special Agent) representing the NMFS [insert Region] 

Regional Administrator or Office of Law Enforcement with respect to the taking of a 

stranded marine mammal.

4. Manage any and all expenses that the Participant incurs associated with the activities 

authorized by this Agreement. NMFS does not have funds to reimburse volunteers for 

expenses incurred in responding to stranding events. However under the marine 

mammal UME process, funding may be available for costs associated with specific 

analyses and additional requests in accordance with section 405 of the MMPA UME 

National Contingency Fund and in coordination with the Working Group on Marine 

Mammal Unusual Mortality Events. Additionally, competitive funding opportunities for 

Stranding Network Participants may be available through the Prescott Stranding 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article II 

 

9

Assistance Grant Program (see http://www.nmfs.noaa.gov/pr/health/prescott/). 

5. Promote human and public safety by taking precautions against injury or disease to any 

network personnel, volunteers, and the general public when working with live or dead 

marine mammals. 

6. Notify [immediately or] within 24 hours the NMFS Stranding Coordinator of learning of 

any diseases of concern (e.g., emerging, reportable, and/or zoonotic diseases) that are 

detected and/or confirmed that could be a potential hazard for public health or animal 

health (NMFS will provide guidance on reportable diseases as it becomes available); 

7. Transfer of marine mammal parts (50 CFR 216.22 and 216.37): 

a. Non-diagnostic parts, tissues, cells, gametes, or cell cultures to be used for 

scientific research, species enhancement, or education shall be transferred only to 

persons or labs that have received prior written authorization from the NMFS 

MMPA/ESA scientific research permit or a Regional Authorization. A unique 

field number assigned by NMFS (e.g., NMFS Registration Number) or the 

Participant must be marked on or affixed to the marine mammal part or container. 

b. Diagnostic parts, tissue samples, fluid specimens, parts, or cells may be 

transferred to labs within the United States for diagnostic use without any 

additional authorizations. 

8. Work cooperatively with the NMFS and the USCG in a hazardous waste spill (i.e., oil 

spills) ICS if implemented. 

9. Notify the NMFS Regional Administrator in writing within 30 days of any changes in its 

Designee organizations, key personnel (see Attachment A), capabilities, and/or 

geographic area of response. 

10. If requested, the Participant shall coordinate with NMFS to develop and implement a 

media plan relating to stranding events. 

11. Photo documenting (still or video) for other than diagnostic or identification purposes 

(such as dorsal fin identification, documentation of lesions, scars, etc.) must not interfere 

or influence the conduct of the stranding responders and response in any way or cause 

additional harassment to marine mammals. 

12. If requested by the NMFS Regional Stranding Coordinator, the Participant will provide 

copies of any photographs, films, and/or videotapes documenting any 

stranding, particularly for those strandings when human interactions are 

reported or suspected. Reimbursement for this request is subject to 

negotiation between NMFS and the Participant. Any photography, film 

and/or videotape of the stranding response used for educational or 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article II 

 

10

commercial purposes of stranding response should by the Participant

should include a credit, acknowledgment, or caption indicating that the 

stranding response was conducted under a Stranding Agreement 

between NMFS and the Participant under the authority of the MMPA. 

NMFS will not reproduce, modify, distribute, or publicly display the 

photograph, film, and/or videotape without consent of the owner, unless 

required to release a copy under Federal law or order (such as the 

Freedom of Information Act). 

13. By its nature, the handling of stranded marine mammals (dead or alive) is potentially a 

dangerous activity. The Participant shall indemnify and hold harmless 

the United States Government from any and all losses, damages, or 

liability -or claims therefore -on account of personal injury, death, or 

property damage of any nature whatsoever, arising out of the activities 

of the Participant, his/her/its employees, his/her/its qualified 

representatives, designees, subcontractors, volunteers, or agents. 

Liability for person(s) acting under this agreement is addressed in 

sections 406(a) and (b) of the MMPA [16 U.S.C. 1421(e)]. 

14. Provide accurate and honest information in all reports to NMFS. 

15. Except where a longer period is specified (e.g., 15 years for rehabilitation cases, see 

Attachment D NMFS Best Practices for Marine Mammal Stranding Response, 

Rehabilitation, and Release – Standard for Rehabilitation Facilities), maintain records 

upon which required reports are based for at least 3 years on-site. 

16. Upon request by the NMFS Regional Administrator, allow the Regional Stranding 

 Coordinator, other appropriate NMFS employees, or any other appropriate person duly 

 designated by the Regional Administrator, to inspect the facilities and inspect and/or 

 request records that pertain to stranding network activities. 

17. [Reserved Verbally report any right whale sightings that occur or are reported as part of 

 their normal activities. See Attachment B for contact information. 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article III 

 

11

ARTICLE III 

Dead Animal Response 

Reserved 

OR

A. The Participant may take species of marine mammals under the MMPA for the 

purpose of dead animal investigation and response.

Subject to the conditions contained in this Agreement, the MMPA, and the implementing 

regulations, the Participant may take dead stranded marine mammals or parts therefrom for the 

collection of data on the health and health trends of wild populations, for the detection of marine 

mammal UMEs, for the detection of signs of human interaction, for research or education on 

marine mammal biology and life history, for the determination of cause of death, for the 

detection of human caused and natural mortality, or for other research as deemed appropriate by 

the NMFS. These activities specifically include: obtaining measurements and biological samples 

from dead stranded marine mammals; disposing, or assisting in the disposal, of dead stranded 

marine mammals at an appropriate landfill or other suitable location; and taking and transporting 

dead stranded or floating dead marine mammals, or parts therefrom, to facilities or individuals 

approved pursuant to 50 CFR. 216.22 for scientific research, maintenance in a properly curated, 

professionally accredited scientific collection, or for educational purposes. 

B. Terms and Conditions for Dead Animal Response 

1. Response 

a. The Participant shall respond as practicable to reports of dead stranded marine 

mammals within the geographic range or response specified under Article I, 

Number B.2. [Reserved {If the Participant is the closest and/or first responder, 

the Participant is considered to be the on-site coordinating organization and is in 

charge of all on-site activities.}] In certain circumstances such as a UME, mass 

stranding, or endangered marine mammal stranding, NMFS may implement the 

ICS structure and designate an on-site coordinator to be in charge of the event 

(see Article II C9). In all situations, the Participant will cooperate with Federal, 

state and local government officials and employees and other stranding network 

participants when responding to these strandings. If the Participant receives a 

verified report of a dead stranded marine mammal and does not have the 

capability to respond appropriately to the report, the Participant shall notify the 

NMFS Regional Stranding Coordinator and/or adjacent stranding network 

participants within 24 hours if feasible. 

 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article III 

 

12

b. If the Participant leaves a dead animal at the stranding site or in the case of a UME 

or mass stranding response, the Participant shall, if feasible, mark each animal 

with a tag or mark, such as roto-tags or grease stick, to assist with data collection 

and to prevent multiple reports on the same animal(s). 

 c. If requested by NMFS Regional Stranding Coordinator and if feasible and 

practicable, the Participant will assist with stranding response in neighboring 

areas outside the Participant geographic range (specified in Article I B2). 

2. Data Collection and Reporting. The Participant shall collect and provide the following 

information for each stranded marine mammal they respond to: 

 a. Complete the NOAA Form 89-864, OMB #0648-0178 (the Marine Mammal 

Stranding Report - “Level A" Form) for each stranded marine mammal. 

Completed forms shall be sent to the NMFS Regional Stranding Coordinator via 

the NMFS National Marine Mammal Stranding Database or in writing (see 

Attachment B), no later than 30 days after responding to the stranding event. If 

requested by the NMFS Regional Stranding Coordinator and if feasible, the 

Participant shall provide preliminary data (verbal or written) from the Level A - 

Marine Mammal Stranding Report within 24 hours. 

 b. As resources are available, collect additional Level B and Level C data.

c. Notify the Regional Stranding Coordinator of the following cases [immediately 

or] within 24 hours or according to the specific reporting guidance provided by 

the Stranding Coordinator: 

 1). possible or confirmed human interactions (including military activity), 

 2). suspected UMEs, 

 3). extralimital or out-of-habitat situations, 

 4). mass stranding events and/or mass mortalities, 

 5). large whale strandings, and 

 6). any stranding involving endangered or threatened species or identified 

species of concern [list species] 

 

 d. In certain circumstances (e.g., listed or rare species stranding, UME, possible 

human interaction case, extralimital or out-of-habitat situation), the NMFS 

Regional Stranding Coordinator may request necropsies be conducted by a 

Necropsy Team Leader, or that additional and expedited reporting (verbal or 

written) of Level B and C data such as analytical results and necropsy reports if 

available. NMFS will not reproduce, modify, distribute, or publish the data 

without consent of the Participant unless required to release the data under 

Federal law or order (such as the Freedom of Information Act); 

 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article III 

 

13

e. Collect and make available any gear, debris, or other objects (e.g., bullets, arrows, 

net webbing, etc.) recovered from a stranded marine mammal that may be 

evidence of human interaction. The Participant must comply with chain of 

custody procedures or any other instructions as specified and supported by NMFS 

[insert Region] and/or NMFS Office of Law Enforcement personnel. 

3. Parts Disposition. Diagnostic parts, tissue samples, fluid specimens, parts or cells may 

 be transferred to labs within the United States for diagnostic use without any additional 

 authorizations. For non-diagnostic parts or samples: 

a. Retention: Marine mammal parts may be retained by the Participant for 

education and/or research purposes, provided they are properly indicated in the 

“Specimen Disposition” field of NOAA Form 89-864, OMB #0648-0178 (the 

Marine Mammal Stranding Report - “Level A" Form). Parts and/or containers 

must be marked with the field identification number assigned by the Participant or 

by NMFS (i.e., NMFS registration number). Authorization to take parts from 

ESA listed species in the [insert Region] is currently provided under MMPA/ESA 

Permit No. 932-1489-09, as amended, issued to the NMFS Marine Mammal 

Health and Stranding Response Program Coordinator, and requires authorization 

and direction from the NMFS Regional Stranding Coordinator in the event of a 

stranding involving a threatened or endangered marine mammal, prior to any 

action by the Participant. 

b. Transfer: Report to the NMFS Regional Administrator (See Attachment B) 

within 30 days of the stranding event, the transfer of any parts salvaged from the 

stranded marine mammal collected under this Agreement as required by 50 CFR 

216.22 [or 50 CFR 216.37]. The Participant must provide the institution name 

where specimen materials have been deposited and ensure that the retained or 

transferred parts are marked with the field identification number or assigned 

NMFS Registration number in the “Specimen Disposition” field on the NOAA 

Form 89864, OMB #0648-0178 (the Marine Mammal Stranding Report – Level 

“A” Form) and ensure that retained or transferred parts are marked with the field 

identification number or the NMFS Registration Number. If parts are being 

transferred, the Participant must ensure the receiving institution is authorized by 

the NMFS Regional Administrator to receive marine mammal parts. 

4. Site cleanup. The Participant shall make every reasonable effort to assist in the clean up 

of beach areas where their activities (e.g., necropsy or specimen collection) under this 

Agreement that may contribute to soiling of the site. 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article IV 

 

14

ARTICLE IV 

Live Animal Response: First Response 

Reserved 

OR

A. The Participant may take species of marine mammals covered under the MMPA for 

the purpose of live stranding first response (initial assessment and care at the site of 

stranding and assist in the appropriate disposition of the animal), beach triage, beach 

release, temporary holding for assessment and triage, translocation and/or transportation 

to a NMFS authorized rehabilitation center within the [insert Region]. 

1. The Participant must take live stranded marine mammals in a humane manner (as defined 

in 50 CFR 216.3, see Attachment A) for the protection or welfare of the marine mammal. 

[Reserve for those w/ Article III authorization: If the animal dies during the course of 

response and/or investigation, then the terms and responsibilities contained in Article III 

of this Agreement become operative.] In addition to the activities authorized in Articles 

I, II, (reserved Article III), the Participant is authorized to implement the following 

activities under this article: 

 a. Take measurements and collecting blood or other diagnostic samples from live 

 stranded marine mammals for health assessment. 

b. Return live stranded marine mammals, as directed by the NMFS Regional 

Stranding Coordinator, to their natural habitat and tagging such animals 

 c. Transport live stranded marine mammals for rescue and rehabilitation to a NMFS 

 approved rehabilitation facility or temporary holding facility. 

 d. Perform humane euthanasia. Euthanasia shall only be performed by the attending 

veterinarian or by a person acting under the direction of the attending veterinarian 

and following approved guidelines such as those referenced in Attachment C 

(2007 Report of the American Veterinary Medical Association Panel on 

Euthanasia, 2nd Edition of the CRC Handbook of Marine Mammal Medicine, 

2006 Journal of the American Association for Zoo Veterinarians). When 

using controlled drugs, such person(s) shall comply with all applicable state and 

Federal laws and regulations (i.e., registered with the Drug Enforcement 

Administration). Authorization for euthanasia of ESA-listed species provided 

under MMPA/ESA Permit No. 932-1489-09, as amended, and requires prior 

approval and direction from the NMFS Regional Stranding Coordinator. 

2. This Agreement does not authorize any projects involving “intrusive research” (as 

 defined in 50 CFR 216.3). Measurements or sampling for scientific research purposes 

 (i.e., outside the scope of accepted diagnostic and treatment practices for the care of an 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article IV 

 

15

 animal) must be authorized under a NMFS MMPA/ESA scientific research permit. 

B. Terms and Conditions for Live Stranding: First Response 

1. Response 

a. The Participant shall respond to reports of live stranded marine mammals 

[Reserved for taxa and schedule]. [Reserved {If the Participant is the closest 

and/or first responder, the [Participant acronym] is considered to be the on-site 

coordinator and is in charge of all on-site activities.}] In certain circumstances 

such as a UME, mass stranding, or endangered marine mammal stranding, NMFS 

may implement the ICS structure and designate an on-site coordinator to be in 

charge of the event (see Article II C9). In all situations, the Participant will 

cooperate with Federal, state and local government officials and employees and 

other stranding network participants when responding to these strandings. If the 

Participant receives a verified report of a live stranded marine mammal and does 

not have the capability to respond appropriately to the report, the Participant shall 

notify the NMFS Regional Stranding Coordinator without delay. Also, if the 

NMFS Regional Stranding Coordinator receives a report of a live stranded marine 

mammal, the Regional Stranding Coordinator may contact the Participant to 

determine whether the Participant has the capability to respond to the stranding. 

If the Participant cannot respond in a timely manner, the NMFS Regional 

Stranding Coordinator may request another Stranding Network participant to 

respond. 

 b. The Participant shall take all steps reasonably practicable under the circumstances 

 to prevent further injury to any live stranded marine mammal, injury to any 

 network personnel, volunteers, government personnel and the general public. 

 c. The Participant shall tag or mark any animals that are immediately released to 

their natural habitat using a NMFS approved tag, such as one-bolt roto tag, cattle 

ear tags, or freeze branding. Application of other tagging methods must first be 

approved by the NMFS Regional Stranding Coordinator. Tagging and posttagging activities are restricted to monitoring the success of marine mammals 

released to the wild. Any projects outside the scope of monitoring the success of 

a release must be authorized under a NMFS MMPA/ESA scientific research 

permit. 

d. If the Participant determines that it is necessary to temporarily hold or triage a 

stranded marine mammal at a separate site from the NMFS approved 

rehabilitation facility, the animal(s) cannot be moved until the Participant obtains 

verbal approval from the NMFS Regional Stranding Coordinator. 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article IV 

 

16

Written documentation of the need for an interim location and written 

concurrence from the NMFS Regional Stranding Coordinator with any associated 

conditions must be provided at the earliest time practicable within 24 hours. 

e. If the Participant considers responding to an “out-of-habitat” or free-swimming 

marine mammal [Reserve: replace marine mammal with listed species and 

cetaceans; or listed species and pinnipeds, or listed species] in distress (e.g., 

entanglement), the Participant must first contact the NMFS Regional Stranding 

Coordinator for approval and discuss plans for live capture and/or needs for 

assistance. The NMFS Regional Stranding Coordinator may require a NMFS 

employee to be present at the time of capture. 

f. [Reserved {The Participant shall follow the guidance provided by the [insert 

Region] in Attachment E, Disposition of Live Stranded Marine Mammals, and 

shall consult with the NMFS Stranding Coordinator and the attending veterinarian 

to make a determination regarding immediate release, rehabilitation, or euthanasia 

of live stranded marine mammals or cetaceans}]. 

2. Data Collection and Reporting. The Participant shall collect and provide the following 

information for each stranded marine mammal they respond to: 

 a. Complete the NOAA Form 89-864, OMB #0648-0178 (the Marine Mammal 

Stranding Report - “Level A" Form) for each stranded marine mammal. 

Completed forms shall be sent to the NMFS Regional Stranding Coordinator via 

the NMFS National Marine Mammal Stranding Database or in writing (see 

Attachment B), no later than 30 days after responding to the stranding event. If 

requested by the NMFS Regional Stranding Coordinator and if feasible, the 

Participant shall provide preliminary data (verbal or written) from the Level A - 

Marine Mammal Stranding Report within 24 hours. 

b. If temporarily holding a stranded animal prior to transferring to a NMFS 

approved rehabilitation facility acting in accordance with this Article, the 

Participant shall complete the NOAA Form 89878, OMB # 0648-0178 (the 

Marine Mammal Rehabilitation Disposition Report). This report shall be sent to 

the NMFS Regional Stranding Coordinator via the NMFS National Marine 

Mammal Stranding Database or in writing (see Attachment B), no later than 30 

days after responding to the stranding event. If requested by the NMFS Regional 

Stranding Coordinator and if feasible, the Participant shall provide preliminary 

data (verbal or written) from the Marine Mammal Rehabilitation Disposition 

Form within 24 hours. 

 c. As resources are available, collect additional Level B and Level C data. 

 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article IV 

 

17

d. Notify the NMFS Regional Stranding Coordinator of the following cases 

[immediately or] within 24 or according to the specific reporting guidance 

provided by the Stranding Coordinator: 

 1). possible or confirmed human interactions (including military activity), 

 2). suspected UMEs, 

 3). extralimital or out-of-habitat situations (see B.1.e. of this Article), 

 4). mass stranding events and/or mass mortalities, 

 5). large whale strandings, and 

 6). any stranding involving endangered or threatened species or identified 

species of concern [list species] 

 e. In certain circumstances (e.g., UME, possible human interaction case, extralimital 

or out-of-habitat situation), the NMFS Regional Stranding Coordinator may 

request additional and expedited reporting (verbal or written) of Level B and C 

data such as analytical results and necropsy reports if available. NMFS will not 

reproduce, modify, distribute, or publish the data without consent of the 

Participant unless required to release the data under Federal law or order (such as 

the Freedom of Information Act); 

 f. Collect and make available any gear, debris, or other objects (e.g., bullets, arrows, 

net webbing, etc.) recovered from a stranded marine mammal that may be 

evidence of human interaction. The Participant must comply with chain of 

custody procedures or any other instructions as specified and supported by NMFS 

[insert Region] and/or NMFS Office of Law Enforcement personnel. 

[Reserved for those without Article III authorization: 

3. Parts Disposition. Diagnostic parts, tissue samples, fluid specimens, parts or cells may 

 be transferred to labs within the United States for diagnostic use without any additional 

 authorizations. For non-diagnostic parts or samples: 

a. Retention: Marine mammal parts may be retained by the Participant for 

education and/or research purposes, provided they are properly indicated in the 

“Specimen Disposition” field of NOAA Form 89-864, OMB #0648-0178 (the 

Marine Mammal Stranding Report - “Level A" Form). Parts and/or containers 

must be marked with the field identification number assigned by the Participant or 

by NMFS (i.e., NMFS registration number). Authorization to take parts from 

ESA listed species in the [insert Region] is currently provided under MMPA/ESA 

Permit No. 932-1489-09, as amended, issued to the NMFS Marine Mammal 

Health and Stranding Response Program Coordinator, and requires authorization 

and direction from the NMFS Regional Stranding Coordinator in the event of a 

stranding involving a threatened or endangered marine mammal, prior to any 

action by the Participant. 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article IV 

 

18

b. Transfer: Report to the NMFS Regional Administrator (See Attachment B) 

within 30 day of the stranding event, the transfer of any parts salvaged from the 

stranded marine mammal collected under this Agreement as required by 50 CFR 

216.22 [or 50 CFR 216.37.] The Participant must provide the institution name 

where specimen materials have been deposited and ensure that the retained or 

transferred parts are marked with the field identification number or assigned 

NMFS Registration number in the “Specimen Disposition” field on the NOAA 

Form 89864, OMB #0648-0178 (the Marine Mammal Stranding Report – Level 

“A” Form) and ensure that retained or transferred parts are marked with the field 

identification number or the NMFS Registration Number. If parts are being 

transferred, the Participant must ensure the receiving institution is authorized by 

the NMFS Regional Administrator to receive marine mammal parts. 

4. Site Cleanup. The Participant shall make every reasonable effort to assist in the clean up 

of beach areas where their activities (e.g., euthanasia, necropsy, or specimen collection) 

under this Agreement. 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article V 

 

19

ARTICLE V 

Live Animal Response: Rehabilitation and Final Disposition 

Reserved 

OR

A. The Participant may take live stranded marine mammals in a humane manner with 

the goal of rehabilitation and release. If the animal dies during the course of rehabilitation, 

then the terms and responsibilities contained in Article III of this Agreement become 

operative. In addition to the activities authorized in Articles I, II, (reserved III, IV) of this 

Agreement and subject to the conditions contained in this Agreement, the MMPA, and the 

implementing regulations, the Participant is authorized to implement the following 

activities under this article: 

1. In accordance with applicable regulations and NMFS guidelines and best practices, 

transfer marine mammals to another NMFS approved rehabilitation facility within the 

[Region] for: 

a. release back to the wild; 

 

b. temporary placement in a scientific research facility holding a current NMFS 

scientific research permit and a United States Department of Agriculture Animal 

and Plant Health Inspection Service (APHIS) Research License; or 

c. permanent disposition at an authorized facility (i.e. holds an APHIS 

 exhibitors license {7 U.S.C. 2131 et seq.}) after consultation with, and 

 authorization by, the NMFS Office of Protected Resources Permits, Conservation 

 and Education Division. 

2. Conduct scientific research on stranded animals in a rehabilitation facility, only if the 

responsible individual has a NMFS scientific research permit and the facility holds an 

APHIS research license in accordance with the Animal Welfare Act (see 50 CFR 216.27 

(c)(6)). 

3. Return rehabilitated stranded marine mammals to their natural habitat. A decision 

 regarding whether or not a marine mammal has the potential to be released must be made 

 as early as possible during the rehabilitation period. Any marine mammal eligible for 

 release must be released as early as possible and no later than six months after being 

 taken for rehabilitation unless the attending veterinarian determines that: the marine 

 mammal might adversely affect marine mammals in the wild; release is unlikely to be 

 successful due to the physical condition and behavior of the marine mammal; or more 

 time is needed to make a determination. Release plans must be submitted to the NMFS 

 Regional Administrator at least 15 days prior to the release, unless advanced notice is 

 waived by the NMFS Regional Administrator. The NMFS Regional Administrator may 

 require the participant to provide additional information, modify the release plan, or 

 dispose of the marine mammal in another manner (see 50 CFR 216.27(a) and the 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article V 

 

20

NMFS/FWS Best Practices for Marine Mammal Stranding Response, Rehabilitation, and 

 Release – Standards for Release.) 

4. Tag rehabilitated stranded marine mammals, strictly for purposes of monitoring success 

of release to the wild using a NMFS approved tag, such as one-bolt roto-tag, cattle ear 

tags, or freeze branding. Application of other tagging methods must first be approved by 

the NMFS Regional Stranding Coordinator. Tagging and post-tagging activities are 

restricted to monitoring the success of marine mammals released to the wild. Any 

projects outside the scope of monitoring the success of a release must be authorized 

under a NMFS MMPA/ESA scientific research permit. 

5. Perform humane euthanasia. Euthanasia shall only be performed by the attending 

veterinarian or by a person acting under the direction of the attending veterinarian and 

following approved guidelines such as those referenced in Attachment C (2007 Report of 

the American Veterinary Medical Association Panel on Euthanasia, 2nd Edition of the 

CRC Handbook of Marine Mammal Medicine, 2006 Journal of the American Association 

for Zoo Veterinarians). When using controlled drugs, such person(s) shall comply with 

all applicable state and Federal laws and regulations (i.e., registered with the Drug 

Enforcement Administration). Authorization for the euthanasia of ESA-listed species 

provided under MMPA/ESA Permit No. 932-1489-09, as amended, and requires prior 

approval and direction from the NMFS Regional Stranding Coordinator. 

B. Terms and Conditions for Live Animal Response: Rehabilitation, Release, or Final 

Disposition Determination 

1. Rehabilitation 

a. The Participant shall comply with laws, regulations, policies, and/or 

 guidelines applicable to or promulgated by NMFS that apply to activities under 

 this Agreement. The Participant must also have all applicable Federal, state, and 

 local permits for rehabilitation facilities, and must comply with all Federal, state,

 and municipal laws related to operations of the facility. 

 b. The Participant shall be responsible for the custody of any living marine 

 mammal taken pursuant to this Article using standards for humane care and for 

 practicing accepted medical evaluation and treatment as described in the NMFS 

 Best Practices for Marine Mammal Stranding Response, Rehabilitation, and 

 Release – Standard for Rehabilitation Facilities (Attachment D). 

c. The Participant shall not exceed their maximum holding capacity for cetaceans 

and pinnipeds based on the minimum standard space requirements, the number of 

animals housed in each holding area, and the availability of qualified personnel as 

described in the NMFS Best Practices for Marine Mammal Stranding Response, 

Rehabilitation, and Release – Standard for Rehabilitation Facilities (Attachment 

D) unless a written waiver is first received from the NMFS Regional 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article V 

 

21

Administrator. The NMFS Regional Stranding Coordinator may offer assistance 

for relocating animals to another rehabilitation facility and in supporting decisions 

to euthanize when necessary. Other considerations for determining maximum 

holding capacity include: 

 (1) On-site veterinary care, volunteer support, and experienced staff; 

 (2) Adequate food and medical supplies and medical test capabilities; 

 (3) Isolation for marine mammals; 

(4) Adequate water quality; 

(5) Limited public access; and 

(6) Ability to maintain current, accurate and thorough records 

 d. The Participant shall follow contingency plans approved by NMFS for the care of 

marine mammals in rehabilitation during planned events (e.g., construction) or 

unexpected events such as mass strandings, UMEs, natural disasters (e.g., 

hurricanes, harmful algal blooms, El Niño), and/or hazardous waste spills. 

 e. The Participant shall isolate rehabilitating marine mammals from other wild or 

 domestic animals and from any animal in permanent captivity. 

 f. The Participant shall prohibit the public display and training for performance of 

 stranded rehabilitating marine mammals as required by 50 CFR 216.27(c)(5). 

 This includes any aspect of a program involving interaction with the public. 

g. The Participant shall follow any additional requirements for rehabilitation (e.g., 

isolation) and release prescribed by NMFS in consultation with the Working 

Group for Marine Mammal Unusual Mortality Events during a marine mammal 

UME, as recommended in the National Contingency Plan for Response to 

Unusual Marine Mammal Mortality Events; D.W. Wilkinson, NOAA Technical 

Memorandum NMFS-OPR-9, September 1996. 

h. The Participant must temporarily refuse admittance of new cases of stranded 

 marine mammals due to the severity of a disease outbreak when instructed by the 

 NMFS Regional Stranding Coordinator, in consultation with the UME Working 

 Group or other experts, if diseases of concern have been reported (e.g. diseases 

 associated with a UME, or any emerging or zoonotic diseases). 

i. The Participant shall not transfer a marine mammal being rehabilitated under this 

 Agreement to another facility without prior approval form the NMFS Regional 

 Stranding Coordinator. 

[Reserve: 

j. If a marine mammal dies while in rehabilitation, Article III applies.] 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article V 

 

22

2. Release 

a. Release Recommendation. The Participant shall make a final written 

 recommendation for each animal in rehabilitation as early as possible, and no 

 more than six months after its date of rescue, for release or non-release 

 determination to the NMFS Regional Administrator according to any 

 applicable NMFS release guidelines and regulations including 50 CFR 216.27 

 (release, non-releasable, and disposition under special exception permits for 

 rehabilitated marine mammals). This final recommendation shall include a 

 release recommendation signed by the Participant’s attending veterinarian, 

 attesting that the marine mammal is medically and behaviorally suitable for 

 release in accordance with the NMFS Standards for Release, and a concurrence 

 signature from the Participant’s Authorized Representative or Signatory of the 

 Stranding Agreement (see Attachment D, NMFS /FWS Best Practices for 

 Marine Mammal Stranding Response, Rehabilitation, and Release – Standards 

 for Release). 

 b. Release Plan. If the Participant recommends release, a release plan must also be 

included with the final recommendation letter. This information must be 

submitted to and approved by the NMFS Regional Administrator at least 15 days 

prior to the release, unless advanced notice is waived by the NMFS Regional 

Administrator, as required by 50 CFR 216.27(a). 

3. Data Collection and Reporting 

a. Diseases of Concern Reporting. The Participant shall notify, [immediately or] 

within 24 hours, the NMFS Regional Stranding Coordinator of learning of any 

diseases of concern (e.g., emerging, reportable, and/or zoonotic diseases) that are 

detected and/or confirmed that could be a potential hazard for public health or 

animal health (NMFS will provide guidance on Reportable Diseases); 

 b. Disposition Reports. Upon release or other disposition of any marine mammal 

under this Article, the Participant shall complete the NOAA Form 89878, OMB # 

0648-0178 (the Marine Mammal Rehabilitation Disposition Report Form). 

Completed forms shall be sent to the NMFS Regional Stranding Coordinator via 

the NMFS National Marine Mammal Stranding Database or in writing (see 

Attachment B), no later than 30 days after final disposition of the marine 

mammal. If requested by the NMFS Regional Stranding Coordinator and if 

feasible, the Participant shall provide preliminary data (verbal or written) from the 

Marine Mammal Rehabilitation Disposition Report within 24 hours. 

c. [Reserved {Annual Summary Reports. The Participant shall submit an annual 

 report (due January 31 each year) summarizing the Participant’s rehabilitation 

 activities for the past calendar year. NMFS will not reproduce, modify, distribute, 

 or publish the data without consent of the Participant unless required to release 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article V 

 

23

the data under Federal law or order (such as the Freedom of Information Act). 

The reports shall include the following for each animal in rehabilitation: 

i. Species and field number 

ii. If the animal was released: 

(a) Date, location of release (latitude and longitude). 

(b) Type and specifics of post-release monitoring (roto-tag, satellite, etc.) and 

any roto-tag or freeze brand numbers used. 

(c) Photos if possible. 

(d) Duration of post-release monitoring. 

(e) Status of post-release monitoring. 

(f) Indications from monitoring relative to success of the rehabilitation 

effort. 

(g) Disposition of tracking data if applicable. 

iii. If the animal was transferred to permanent care: 

(a) Date of physical transport (if applicable) 

(b) Location of permanent care 

iv. If the animal was euthanized, provide the date of euthanasia. 

v. If the animal died, provide the date of death. 

[Reserved for those without Article III authorization:] 

4. Parts Disposition. Diagnostic parts, tissue samples, fluid specimens, parts or cells may 

 be transferred to labs within the United States for diagnostic use without any additional 

 authorizations. For non diagnostic parts or samples: 

a. Retention: Marine mammal parts may be retained by the Participant for 

education and/or research purposes, provided they are properly indicated in the 

“Specimen Disposition” field of NOAA Form 89-864, OMB #0648-0178 (the 

Marine Mammal Rehabilitation Disposition Report Form). Parts and/or 

containers must be marked with the field identification number assigned by the 

Participant or by NMFS (i.e., NMFS registration number). Authorization to take 

parts from ESA listed species in the [insert Region] is currently provided under 

MMPA/ESA Permit No. 932-1489-09, as amended, issued to the NMFS Marine 

Mammal Health and Stranding Response Program Coordinator, and requires 

authorization and direction from the NMFS Regional Stranding Coordinator in 

the event of a stranding involving a threatened or endangered marine mammal, 

prior to any action by the Participant. 

b. Transfer: Report to the NMFS Regional Administrator (See Attachment B) 

within 30 days of the stranding event, the transfer of any parts salvaged from the 

stranded marine mammal collected under this Agreement as required by 50 CFR 

216.22 [or 50 CFR 216.37.] The Participant must provide the institution name 

where specimen materials have been deposited and ensure that the retained or 

transferred parts are marked with the field identification number or assigned 

NMFS Registration number in the “Specimen Disposition” field on the NOAA 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article V 

 

24

Form 89864, OMB #0648-0178 (the Marine Mammal Rehabilitation Disposition 

Report Form) and ensure that retained or transferred parts are marked with the 

field identification number or the NMFS Registration Number. If parts are being 

transferred, the Participant must ensure the receiving institution is authorized by 

the NMFS Regional Administrator to receive marine mammal parts. 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article VI 

 

25

ARTICLE VI 

Participant’s Authorized Personnel [and Designees] 

Reserved 

OR 

A. Personnel and Volunteers 

Takings of marine mammals authorized in this Agreement may only be directed by the 

Participant’s personnel and trained volunteers identified by the Participant in writing to the 

NMFS Regional Administrator. The Participant may use other (i.e., not previously identified to 

NMFS) volunteers to carry out activities in this Agreement only if they are under the close 

direction of previously identified trained personnel or volunteers. The Participant may not 

delegate authority to take marine mammals to another person except as provided in this article. 

In the event of changes in key personnel, the prospective Participant shall notify the NMFS 

Regional Administrator in writing (see Attachment B) [within 30 days] and provide a description 

of the experience of new key personnel for review and approval by NMFS. New key personnel 

must be meet the qualification terms identified in the NMFS Best Practices for Marine Mammal 

Stranding Response, Rehabilitation, and Release - Evaluation Criteria for a Marine Mammal 

Stranding Agreement (Attachment D). 

B. Untrained Citizens 

If the Participant requests the assistance of untrained citizens (e.g., during a mass stranding), the 

Participant is responsible for the actions of those citizens during the response; must take 

precautions against injury or disease to those volunteer citizens; and must ensure that the 

citizens’ actions do not cause unnecessary harassment of marine mammals. 

Reserve all or C.1. and C.2.: 

C. Designee Organizations. 

1. Authorization for Designee Organization(s). The Participant may designate an 

 organization, or institution, to act on behalf of the Participant as a designee in accordance 

 with this Agreement. For the purposes of this Agreement, the term designee does not 

 refer to individual personnel/volunteers of the Participant’s organization, or to individual 

 personnel/volunteers of the Designee organization or institution. Any designation 

 requires prior written approval from the NMFS Regional Administrator (Appendix A). 

 Any organization or institution so designated shall be deemed an agent of the Participant 

 and NMFS, and is subject to ALL applicable provisions of this Agreement as well as 

 applicable laws, regulations, and guidelines. The Participant must provide oversight of 

 their designee organization(s). Any breach of the provisions of this Agreement by a 

 designee of Participant shall be deemed a breach by the Participant. 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article VI 

 

26

2. Purpose of Designee Organization(s). The purpose of a designee organization(s) is to 

assist the Participant with improved sub-region coordination, response, and/or 

rehabilitation capability within the Participant’s geographic area of responsibility. The 

ability to train and oversee Designees helps create new organizations and build the 

Stranding Network capacity. NMFS will evaluate designee organizations based on the 

Participant’s justification for geographic need, enhancement of response capabilities, and 

level of experience provided by the designee organization. 

3 Terms and Conditions for Adding Designee(s): To request the addition of a Designee 

Organization to the Participant’s Stranding Agreement, the Participant must submit 

required written information (see below and Attachment D, NMFS Best Practices for 

Marine Mammal Stranding Response, Rehabilitation, and Release - Evaluation Criteria 

for a Marine Mammal Stranding Agreement). This information must be received at least 

30 days prior to any prospective designation, to the NMFS Regional Administrator (see 

Attachment B) for review and approval. NMFS will respond in writing to the 

Participant’s request within 30 days of receipt of the request with an approval, rejection, 

or request for more information. 

 a. Complete name of the designee person, organization, or institution. 

 b. Resumes or CVs of all key personnel for Designees including evidence 

 of relevant training; 

 c. Justification Statement for designation; 

 d. Geographic coverage area for response; 

 e. For rehabilitation facilities, a facility operation plan including 

 personnel, veterinary care, equipment list, and other requirement 

 stated under any applicable NMFS laws, regulations, policies, and 

 guidelines. The Designee must also have all applicable Federal, 

 state, and local permits for rehabilitation facilities; 

 f. Oversight plan including how Participant will monitor the activities of 

 the designee under the Agreement; and 

 g. A copy of written Agreement between the Participant and the Designee 

 that must state that the designee has agreed to abide by all the 

 terms and conditions in the Participant’s Stranding Agreement. 

4. A Designee organization may not be authorized for activities different than or exceeding 

those contained in the Stranding Agreement of the Participant.
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article 

VII 

27

ARTICLE VII 

Rights of States and Local Governments

Nothing in this Agreement shall be construed to affect the rights or responsibilities of other 

Federal, state, or local government officials or employees acting in the course of their official 

duties with respect to taking of marine mammals in a humane manner (including euthanasia) for 

protection or welfare of the marine mammal, protection of public health and welfare or nonlethal removal of nuisance animals (MMPA section 109(h)).
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article VIII 

 

28

 ARTICLE VIII 

Effective Dates, Renewal and Application Procedures 

A. Effective Date 

The terms of this Agreement shall become effective upon the signature by both [Participant 

acronym] and the NMFS [insert Region] Regional Administrator. 

B. Period of Agreement 

1. Duration: Unless terminated as provided in this Agreement, this Agreement shall expire 

 at the end of the following applicable period [insert expiration date]: 

 1 year for new Stranding Network Participants 

 1 year for a Stranding Network Participant on probation 

 3 years for a live animal responder and rehabilitator (Articles IV and V) 

 6 years for a dead animal only responder (Article III only) 

2. Stranding Agreement Renewals: No later than 90 days prior to the expiration date of 

 this Agreement, NMFS will provide the Participant with a written notice of expiration, 

 and prescribe information needed from the Participant for renewal (see NMFS Best 

 Practices for Marine Mammal Stranding Response, Rehabilitation, and Release - 

 Evaluation Criteria for a Marine Mammal Stranding Agreement, Attachment D). No 

 later than 60 days prior to the expiration date, the Participant shall indicate in writing to 

 NMFS (see Contacts, Attachment B.) that a renewal of this Agreement is requested and 

 shall provide the prescribed information. Following NMFS review of the submitted 

 information to determine if Participant meets applicable requirements, the Agreement 

 may be renewed if agreed to in writing by both parties. 

If no written renewal request is received from the Participant, this Agreement 

 becomes null and void upon the above expiration date. 

 

3. Provisional Stranding Agreements Renewals: For new participants, the NMFS 

 Regional Administrator will enter into this Agreement for a provisional period of one 

 year from the effective date. The performance of the Participant will be reviewed to 

 determine if the services provided by the Participant under this agreement have been 

 satisfactory to NMFS. If NMFS determines that the new Participant has satisfied the 

 terms and conditions of this stranding agreement, this Agreement may be extended for a 

 multi-year period. New participants operating without any deficiencies (see Article IX. 

 D), are considered to be in “good standing” under this Agreement. 

4. Denial of Stranding Agreement Renewal: The decision to renew or deny a Stranding 

Agreement is solely at the discretion of the NMFS Regional Administrator and is not 

compelled by the Participant’s adherence to the Stranding Agreement criteria. If the 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article VIII 

 

29

NMFS Regional Administrator denies a renewal request, the denial will be issued in 

writing by certified mail from the NMFS Regional Administrator to the Participant 

within 30 days of the Participant’s submission of a completed application, and will be 

based upon the Regional Administrator’s judgment of: 

 a. Past performance of the Participant; 

 b. Existing capabilities of the Participant; and 

 c. Geographic and programmatic needs of NMFS’ stranding program. 

A Stranding Agreement for which renewal is denied by the NMFS Regional 

 Administrator becomes null and void upon the expiration date listed above.
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article IX 

 

30

ARTICLE IX 

Review, Modification and Termination 

A.. Review 

The NMFS [insert Region] ARA for Protected Resources shall review this Agreement [reserve 

annually or from time to time] for performance adequacy and effectiveness. 

 

B. Modification 

The Participant or the [insert Region] Regional Administrator may request a modification to the 

Stranding Agreement, including, but not limited to, procedural or administrative changes, such 

as a change in contact information, and a request for expansion or reduction of activities 

authorized by this Agreement. A request for authority for additional activities may require 

submission of information identified in Attachment D, NMFS Best Practices for Marine 

Mammal Stranding Response, Rehabilitation, and Release - Evaluation Criteria for a Marine 

Mammal Stranding Agreement. Modifications and reductions in authority, as well as notice of 

issuance or denial of a request for increased authorizations, will be given in writing within 30 

days of receipt of a completed request. The Participant and the NMFS Regional Administrator 

may determine that a new Stranding Agreement is warranted. 

 

C. Suspension or Termination request by Participant

The Participant may request suspension of all or part of this Stranding Agreement for a stated 

period of time, or may terminate this Agreement, upon 30 days written notice to the NMFS 

Regional Administrator. Suspension of the authorization of activities at the request of the 

Participant may be given without prejudice to the reinstatement of authorization or renewal of a 

Stranding Agreement. 

D. Non-Compliance with Stranding Agreement or Violations of Law by Participant 

Except in cases of willfulness, or those in which public health, interest, or safety requires 

immediate suspension, or termination of this Agreement, NMFS shall provide the Participant 

with notice and an opportunity to correct any deficiencies within a time period specified by 

NMFS, in writing, if the Participant fails to satisfy the terms and condition of this Agreement or 

violates any laws, regulations, or guidelines applicable to this Agreement, or Federal, state or 

municipal laws related to stranding network operations. The NMFS Region may take the 

following actions based on the circumstances: 

1. Probation. The Participant may be put on probation for up to three years if deficiencies 

are not corrected. The NMFS Regional Stranding Coordinator and the Participant will 

develop a timetable with reasonable and measurable milestones that must be achieved to 

correct deficiencies during the probation period. Probation requires annual reviews of 

the Participant’s activities for up to three years. 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article IX 

 

31

A participant on probation may not be in “good standing” with the Stranding Network. 

2. Suspension. The NMFS Regional Administrator may suspend the Participant’s 

 authority, or any portion of their authority, as appropriate (e.g., suspend rehabilitation 

 authority, but not live or dead animal response), with 30 days written notice, for up to 1 

 year or until NMFS is satisfied that all deficiencies and violations have been adequately 

 addressed. A notice of suspension listing deficiencies and a timetable with reasonable 

 and measurable milestones required to correct those deficiencies will be issued in 

 writing, delivered in person or by certified mail, from the NMFS Regional Administrator 

 if, in the judgment of the Regional Administrator, the Participant has: 

 

 a. Submitted false information or statements in applications or reports; 

 b. Not satisfied the terms and conditions of the Stranding Agreement; 

 c. Failed to correct deficiencies in a timely manner; or 

 d. Violated applicable Federal, state, or municipal laws, regulations, guidelines, or 

other requirements. 

A participant on suspension is not in “good standing” with the Stranding Network. 

3. Immediate suspension. The NMFS Regional Administrator may require immediate 

suspension of authorization under a Stranding Agreement, or any part of the Agreement, 

without prior notice if, in the judgment of the Regional Administrator, suspension is 

needed to protect marine resources, in cases of willfulness, or as otherwise required to 

protect public health, welfare, interest, or safety, (which includes interest in the welfare 

of marine mammals). During the suspension period, the NMFS Regional Stranding 

Coordinator may ask other Stranding Network participants to respond in the Participant’s 

area of geographic coverage. If the Participant’s Stranding Agreement is suspended 

while animals are in rehabilitation, NMFS reserves the right to either confiscate the 

animals or to arrange for another participant to take over rehabilitation or take custody of 

the animals. A written notice of immediate suspension will be issued in person or by 

certified mail. 

 A participant on immediate suspension is not in “good standing” with the Stranding 

Network. 

4. Termination. The NMFS Regional Administrator may terminate this Agreement, or any 

part thereof, upon at least 30 days written notice to the Participant, delivered in person or 

by certified mail. The Agreement may be terminated for any reason, including the 

Participant’s: 

 a. Submission of false information or statements in applications or reports; 

 b. Failure to satisfy the terms and conditions of the Stranding Agreement; 

 c. Failure to correct deficiencies in a timely manner; or 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Article IX 

 

32

 d. Violation of applicable Federal, state, or municipal laws, regulations, guidelines, 

or other requirements. 

The NMFS Regional Stranding Coordinator may ask another Stranding Network 

participant to respond in the Participant’s area of geographic coverage. If the 

Participant’s Stranding Agreement is terminated while animals are in rehabilitation, 

NMFS reserves the right to either confiscate the animals or to arrange for another 

participant to take over rehabilitation of or to take custody of the animals. 

Termination of the Agreement for any reason shall automatically terminate any 

designations by the Participant to any designee organizations under this Agreement. 

[Reserve for SAs with Designees]:

5. Violations by Designees. Violations by the Participant’s Designee organization are 

 considered to be violations by the Participant. NMFS will address violations by 

 Designees directly with the Participant according to this Article. In addition, NMFS may 

 use the remedy of terminating the designation. 
Pursuant to the terms and conditions described above in this Stranding Agreement 

between [Region] and [Participant], the Participant is authorized (insert applicable 

authorizations): 

 Under Article III to response to strandings of dead marine mammals {reserve 

for taxa}; 

 Under Article IV to provide first response to live stranded marine mammals; 

 Under Article V to rehabilitate and release live stranded marine mammals 

THIS STRANDING AGREEMENT IS ENTERED INTO AND MADE EFFECTIVE THIS 

Date Date 

APPROVED: 

NMFS [Region] Region [Stranding Network Organization] 

Signature of Regional Administrator Signature of Authorized Representative 

 ____________________________________ __________________________________ 

THIS STRANDING AGREEMENT REMAINS IN EFFECT UNTIL: 

Expiration Date: ________________________________________ 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Attachments 

 

34

Appendix A. 

Designees:

Statement of Agreement for designation of authority and responsibilities to 

any organization or institution to act as agents under this Agreement. 

AGREEMENT 

I have read the conditions as stated above for participating in the Stranding Network as an agent 

of the____________________________ (Stranding Network Organization) under its Agreement 

with the National Marine Fisheries Service Region and agree to abide by all applicable 

provisions of the Agreement between the National Marine Fisheries Service Region and 

_______________________________ (Stranding Network Organization). 

NMFS Region 

Authorized Representative 

of Stranding Organization 

Authorized Representative of 

Designee Organization 

Signatures 

Title 

Affiliation 

Date Expiration Date 
Stranding Agreement between [Region] and [Participant], effective xx/xx/xx – xx/xx/xx. Attachments 

 

35

ATTACHMENT LIST

Attachment A. List of Terms and Definitions under 50 CFR 216.3, Glossary of Terms, etc. 

Attachment B. Regional contact information, 24 hour numbers, etc. 

Attachment C: Euthanasia guidance 

Attachment D: NOAA National Marine Fisheries Service Best Practices for Marine 

Mammal Stranding Response, Rehabilitation, and Release Documents: 

 Evaluation Criteria for a Marine Mammal Stranding Agreement (New Applicants 

and Renewals of Existing Participants) 

 Standards for Release 

 Standards for Rehabilitation Facilities 

 Level A Forms (Marine Mammal Stranding Report and Marine Mammal 

Rehabilitation Disposition Report) 

Attachment E: NMFS Southeast Region Disposition of Live Stranded Marine Mammal 

guidance. 
THIS PAGE INTENTIONALLY LEFT BLANK 
POLICIES AND BEST PRACTICES

MARINE MAMMAL STRANDING RESPONSE, 

REHABILITATION, AND RELEASE

Evaluation Criteria for a Marine Mammal Stranding 

Agreements 

(New Applicants and Renewals) 

Prepared by 

Janet E. Whaley, D.V.M. and Laura Engleby February 2009 

NOAA National Marine Fisheries Service 

Marine Mammal Health and Stranding Response Program 

Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

NMFS Evaluation Criteria for a Marine Mammal Stranding Agreement February 2009 

i 

Evaluation Criteria for a Marine Mammal Stranding Agreement 

(New Applicants and Renewals) 

Table of Contents 

1. PURPOSE AND APPLICATION ........................................................................................ 1-1

2. GENERAL EVALUATION CRITERIA FOR ARTICLES III, IV, AND V AUTHORIZATION 2-1

2.1 General Information.........................................................................................................2-1

2.2 General Qualifications for Articles III, IV, and V ...........................................................2-3

3. EVALUATION CRITERIA FOR RESPONSE TO DEAD STRANDED MARINE MAMMALS -

FIRST RESPONSE (ARTICLE III AUTHORIZATION)..................................................... 3-1

3.1 Information for Article III Authorization ........................................................................3-1

3.2 Qualifications for Article III Authorization.....................................................................3-1

4. EVALUATION CRITERIA FOR FIRST RESPONSE, TRIAGE, AND TRANSPORT OF LIVE 

STRANDED MARINE MAMMALS (ARTICLE IV AUTHORIZATION).............................. 4-1

4.1 Information for Article IV Authorization ........................................................................4-1

4.2 Qualifications for Article IV Authorization.....................................................................4-1

5. EVALUATION CRITERIA FOR REHABILITATION AND RELEASE OF LIVE STRANDED 

MARINE MAMMALS (ARTICLE V AUTHORIZATION) .................................................. 5-1

5.1 Information for Article V Authorization..........................................................................5-1

5.2 Qualifications for Article V Authorization ......................................................................5-3

6. EVALUATION CRITERIA FOR DESIGNEE ORGANIZATIONS ......................................... 6-1

6.1 Information for Designee Organizations for Articles III, IV, and V ...............................6-1

6.2 Qualifications for Designee Organizations for Articles III, IV, and V............................6-1
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

NMFS Evaluation Criteria for a Marine Mammal Stranding Agreement February 2009 

ii 

Evaluation Criteria for a Marine Mammal 

Stranding Agreement 

(New Applicants and Renewals) 

Shaded text denotes reserved text at the discretion of the NMFS Regional Administrator. 

(1) To renew an existing Stranding Agreement, the applicant must demonstrate past compliance with 

the terms and responsibilities of their Stranding Agreement, including reporting requirements and 

deadlines. 

(2) For the purpose of network development and expansion of stranding response capabilities in 

geographically remote or low coverage areas [e.g., Alaska, Washington, Oregon, Hawaii, and 

American Territories (i.e., Puerto Rico, the U.S. Virgin Islands, Guam, American Samoa, and the 

Commonwealth of the Northern Marina Islands)], referenced evaluation criteria may be waived based 

on the discretion of the NMFS Regional Administrator. 

(3) If long-term care is not feasible, a plan for disposition of live marine mammals at alternate care 

facilities must be submitted. 
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

NMFS Evaluation Criteria for a Marine Mammal Stranding Agreement February 2009 

1-1 

1. Purpose and Application 

These minimum evaluation criteria have been developed to assist the National Marine Fisheries 

Service [Region] Region (NMFS) in its evaluation of Stranding Agreement renewal requests and new 

Stranding Agreements proposals. Prior to issuing new Stranding Agreements, the NMFS [Region] 

Regional Administrator must determine there is a programmatic and/or geographic need for a 

Stranding Network Participant in the proposed area of response. Geographic or programmatic needs 

are based on, but not limited to, the following factors: the historic number of stranded marine 

mammals in an area, the amount of personnel and resources of stranding network participants with 

existing agreements in the proposed response area, the geographic extent of the proposed response 

area, and the proximity of the existing and prospective stranding network participants to the proposed 

response area. 

The decision to enter into an Agreement under which an organization may take species under the 

Marine Mammal Protection Act for the purpose of stranding response is solely at the discretion of the 

NMFS [Region] Regional Administrator. NMFS [Region] Region is not compelled to enter into or to 

decline to enter into a Stranding Agreement based on an interested party’s adherence with these 

criteria. NMFS weighs the geographical need, programmatic need, level of expertise, stranding 

related activities, cooperation, and criteria listed below when making its determination in determining 

whether to issue a new Stranding Agreement. 
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

NMFS Evaluation Criteria for a Marine Mammal Stranding Agreement February 2009 

2-1 

2. General Evaluation Criteria for Articles III, IV, and V 

Authorization (1)

2.1 General Information 

The existing or prospective Participant should provide the following information to NMFS as part of 

their request to obtain or renew an existing Stranding Agreement with NMFS or upon any significant 

changes to the information: 

1. Participant Contact Information. This should include: 

a. Mailing address, phone number, e-mail, and facsimile for all official correspondence. 

b. Physical address and location of the facility or facilities (if applicable). 

c. Name, title, and contact information for an authorized representative with signatory 

authority for the organization - Authorized Representative (e.g., Executive Director, 

Director, President, CEO, etc.). 

d. [24-hour] contact numbers if applicable, including office, home, and/or cell phone 

numbers of primary responders, key personnel/volunteers, and veterinarians. 

2. Description of Organizational Goals, Capability, and Experience. This should include: 

a. Brief summary of the existing or proposed organization’s mission, goals, and objectives 

and how these complement objectives for the [Region] Regional Stranding Network. 

b. Brief summary on history and type of organization (e.g., university, governmental, nonprofit, aquarium, etc.). 

c. Description of any past or current collaboration with NMFS, other Stranding Network 

participants, researchers, or the public. 

d. Summary of relevant organizational experience with response to live/dead stranding 

events and /or rehabilitating marine mammals within the past three years. 

e. An overview of general capabilities to conduct stranding response. 

3. Proposed Scope and Area of Geographic Response. This should include:

a. Brief summary of the existing or proposed scope of the stranding program (e.g., all 

species of cetaceans, pinnipeds), and whether the request is for response to dead animals 

only, live and dead animals, and/or rehabilitation. 

b. Justification and description of the existing or proposed geographic area of coverage and 

why the area of response is appropriate for the organization (e.g., the amount of 

personnel/volunteers and resources available, relative to shoreline covered, historic 
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

NMFS Evaluation Criteria for a Marine Mammal Stranding Agreement February 2009 

2-2 

number of stranding events, etc.). Latitude and longitude of proposed geographic area 

and maps are especially helpful. 

4. Description of Organizational Structure. This should include: 

a. An overview of staffing, personnel, volunteers, veterinarians, the primary representative, 

and primary responders, including organizational charts, titles, and position descriptions 

as appropriate. 

b. Brief summary of relevant training, experience, and qualifications for key stranding 

response personnel, including primary responders, veterinarians and volunteers as 

appropriate. 

c. Description of how personnel/volunteers will collect, report, and maintain Level A 

stranding data and conduct basic (Level B) tissue sample collection. This should also 

address requirements for accurate and timely reporting. 

d. Description of how volunteers are trained and monitored to ensure quality data collection. 

e. Description of how the organization will keep NMFS informed about any changes in key 

personnel, geographic area of coverage, or capabilities. 

5. Equipment and Resources. This should include: 

a. Description of resources, supplies and equipment currently available to conduct stranding 

response (live and/or dead). This could include, but may not be limited to, information on 

types and availability of necropsy equipment, freezers, trucks, tagging equipment (e.g., 

roto-tags), stretchers, vessels, triage equipment, and transport equipment, and temporary 

and/or permanent pools. 

6. Rapid Response and Investigation Procedures. This should include: 

a. Procedures for stranding response for dead/live stranded marine mammals. 

b. Human health and safety precautions used. 

c. How calls are handled, availability (e.g., 24 hour pager), and which personnel will 

respond. 

d. How necropsies will be coordinated and conducted. 

e. Capabilities and general rescue plan, and plans for animal care (e.g., on-site veterinary 

care) for live animal response including triage, transport, and euthanasia. 

f. Protocols for decision-making when responding to a live animal. 

g. Description of how the organization will coordinate with other Stranding Network 

members and NMFS. 
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

NMFS Evaluation Criteria for a Marine Mammal Stranding Agreement February 2009 

2-3 

7. Any other relevant documentation (permits, authorizations, agreements, etc.) for review prior 

to entering into any Stranding Agreement and at any subsequent time as requested by the 

[Region] Regional Administrator, or when additional documentation is obtained that may 

become relevant to performance under the Agreement. 

8. Documentation of experience, ability, and knowledge (e.g., CV, resume, certificates, letters 

of recommendation, etc.) of key personnel (e.g., primary representative, primary responder). 

Experience can be obtained through paid employment, internships, volunteering, course 

work, and/or NMFS approved training. 

9. For prospective Participants, demonstrate experience working under the direct supervision of 

an existing Stranding Network Participant in good standing or NMFS for at least three years 

or equivalent case load.(2) The prospective Participant may apprentice as a “designee” 

organization under a Stranding Agreement holder to obtain this experience. 

10. Letter(s) of support from peers such as other stranding network organizations (Stranding 

Agreement/Designee organizations), universities/researchers, government agencies, nongovernmental organizations, professional organizations, etc. Such letters of support could 

also be provided from the current Stranding Agreement holder under which the Participant 

received experience and include assurances that the prospective Participant can support 

programmatic and geographic needs in the area (new Stranding Agreement proposals only). 

2.2 General Qualifications for Articles III, IV, and V 

NMFS will evaluate existing and prospective participants based on their demonstrated track record 

and their capabilities in the following areas as described in their request: 

1. Ability to provide description of [24-hour] on-call coverage for the proposed geographic area 

of response (e.g., established “hot-line” number, message phone, staffed pager, etc.). 

2. Demonstrated ability to comply with standard instructions and collect Level A data from 

stranded marine mammals according to established protocols. 

3. Ability to conduct full post-mortem exams, including obtaining histopathology samples and 

other biological samples (if feasible and requested by NMFS). 

4. Willingness and ability to communicate in a professional manner, and demonstrated ongoing 

cooperation with NMFS, other network members, the general public, local and state agencies. 

5. Willingness and ability to cooperate with authorized marine mammal researchers. 

6. Ability to address health and safety when responding to dead or live stranded marine 

mammals, or marine mammals in rehabilitation (e.g., a description of the organization’s 
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

NMFS Evaluation Criteria for a Marine Mammal Stranding Agreement February 2009 

2-4 

operational safety plan or protocols). 

7. Demonstrated experience specific to the marine mammal species that are most likely 

encountered in the proposed area of geographic response. 
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

NMFS Evaluation Criteria for a Marine Mammal Stranding Agreement February 2009 

3-1 

3. Evaluation Criteria for Response to Dead Stranded 

Marine Mammals - First Response 

(Article III Authorization) (1)

In addition to the general criteria, Participants proposing to respond to dead stranded marine 

mammals should provide information that shows the Participant’s plan for implementing Article III of 

the Stranding Agreement, and present evidence that the Participant has the skills, resources, and 

organizational capabilities to be successful. 

3.1 Information for Article III Authorization 

Key Personnel. The prospective Participant should have and maintain one Authorized Representative 

and at least two Primary Responders, at least one of whom will be on-site or supervising when dead 

animals are being examined or handled and is responsible for the day to day operations (i.e., paid and 

unpaid staff).(2) The Authorized Representative has signatory authority for the stranding 

organization and may be the signatory of the stranding agreement (e.g., Executive Director, President, 

CEO, etc.). 

1. Additional personnel may be necessary, commensurate with the proposed geographic area of 

response and frequency of stranding events. 

2. Equipment List. The prospective Participant should demonstrate they have and maintain 

equipment appropriate to dead animal stranding response – i.e., for dead animal response the 

equipment list should at least include items necessary for Level A data collection. 

3.2 Qualifications for Article III Authorization 

1. Key personnel should have experience or comparable training to collect Level A data and if 

possible to collect Level B data (i.e., complete necropsy). Requests should address key 

personnel qualifications as follows: 

a. Experience conducting or observing complete necropsies [on a minimum of six marine 

mammals with at least three of those necropsies on Code 2 animals.](2)

b. Ability to identify species of marine mammals in the field (Code 2).

c. Ability to accurately identify code condition of marine mammals in the field (Code 1-5). 

d. Ability to obtain accurate Level A stranding data and if possible, to conduct basic tissue 

sample (Level B) collection. 

e. Knowledge and experience complying with Level A data reporting requirements. 
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

NMFS Evaluation Criteria for a Marine Mammal Stranding Agreement February 2009 

3-2 

f. Knowledge and experience complying with sampling protocols, sample processing, and 

shipping procedures. 

g. Knowledge of marine mammal anatomy and physiology. 

h. Knowledge of human health and safety precautions including potential zoonotic marine 

mammal disease. 

i. Knowledge of state and local disposal policies and rules. 
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

NMFS Evaluation Criteria for a Marine Mammal Stranding Agreement February 2009 

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4. Evaluation Criteria for First Response, Triage, and 

Transport of Live Stranded Marine Mammals (Article IV 

Authorization) (1)

In addition to criteria in sections I and II, prospective Participants proposing to conduct response to 

live stranded marine mammals should provide information that shows the Participant’s plan for 

implementing Article IV of the Stranding Agreement, and present evidence that the Participant has 

the skills, resources, and organizational capabilities to be successful. 

4.1 Information for Article IV Authorization 

Key Personnel. The prospective Participant should have and maintain one Authorized Representative 

and at least two Primary Responders all with experience in marine mammal stranding response, 

triage, transport, and/or euthanasia, at least one of whom will be on-site or supervising when animals 

are being examined or handled and is responsible for the day to day operations (i.e., paid and unpaid 

staff). The Authorized Representative has signatory authority for the stranding organization and 

may be the signatory of the stranding agreement (e.g., Executive Director, President, CEO, etc.). 

1. Additional personnel may be necessary, commensurate with the proposed geographic area of 

response. 

2. Veterinary Support. The prospective Participant should identify an attending veterinarian and 

identify at least one backup veterinarian or have a contingency plan for when the attending 

veterinarian is not available. Requests should provide documentation of the veterinarian’s 

experience (e.g., CV, certificates, licenses, etc.). 

4.2 Qualifications for Article IV Authorization 

Requests should address key personnel and veterinarian qualifications as follows: 

1. Key personnel should have experience or comparable training in all aspects of live animal 

response: 

a. Experience responding to a minimum of [five] live marine mammal stranding events

(note: a mass stranding is considered to be one event).(2)

b. Experience providing triage and/or transport for a minimum of [three] live stranded 

marine mammals during separate stranding events.(2)

c. Knowledge and experience monitoring marine mammal vital signs. 
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

NMFS Evaluation Criteria for a Marine Mammal Stranding Agreement February 2009 

4-2 

d. Ability to assess the condition of stranded marine mammals and make recommendations 

concerning immediate release, rehabilitation, or euthanasia. 

e. Ability to accurately identify species of marine mammals in field conditions. 

f. Experience responding to at least one mass stranding event (preferred but not required).(2)

g. Ability to [draw blood and] make basic measurements (e.g., length). 

h. Ability to tag a marine mammal (e.g., for situations that involve immediate release 

following assessment). 

i. Ability to communicate professionally with other members of the Stranding Network and 

take direction from NMFS and other on-site coordinators. 

2. Attending veterinarians should meet the following criteria: 

a. Be on-call 24-hours. 

b. Knowledge and demonstrated experience in monitoring marine mammal vital signs. 

c. Ability to assess the condition of stranded marine mammals and make 

recommendations concerning immediate release, rehabilitation, or euthanasia. 

d. Ability to draw blood from a marine mammal. 

e. Have the appropriate registrations and licenses (e.g., registered with the Drug 

Enforcement Administration for handling controlled substances) to obtain the necessary 

medications and euthanasia drugs. 

f. Ability to perform humane euthanasia on marine mammals. 

g. Demonstrated familiarity with marine mammal triage and transport. 

h. Access to a list of veterinarians with marine mammal expertise to consult with if needed. 

i. Compliance with any applicable state requirements for veterinary practice on stranded 

marine mammals. 

3. The prospective Participant should demonstrate knowledge of national, state, and 

local/municipal laws relating to live animal response. 

4. The prospective Participant should have provisions for, and willingness to conduct, humane 

euthanasia as necessary and appropriate. 

5. Equipment List. The prospective Participant should have and maintain equipment appropriate 

to live stranding response, i.e., those items necessary for triage, transport, and/or euthanasia. 

A complete list of equipment available shall be provided by the prospective Participant.
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

NMFS Evaluation Criteria for a Marine Mammal Stranding Agreement February 2009 

5-1 

5. Evaluation Criteria for Rehabilitation and Release of Live 

Stranded Marine Mammals (Article V Authorization)(1,3)

In addition to the criteria in sections II, III, and IV (if applicable), Participants requesting 

authorization to conduct rehabilitation of marine mammals should provide information that shows the 

Participant’s plan for implementing Article V of the Stranding Agreement, and present evidence that 

the Participant has the skills, resources, and organizational capabilities to be successful. The NMFS 

document, “Policies and Best Practices: Standards for Rehabilitation Facilities,” provides additional 

detailed guidance for preparing Stranding Agreement requests. This document can be found at 

http://www.nmfs.noaa.gov/pr/health/eis.htm. Facility operations should be consistent with applicable 

NMFS policies, guidelines, directives, regulations, and other applicable State and Federal policies, 

guidelines, directives, regulations, and laws. 

5.1 Information for Article V Authorization 

The prospective Participant should provide information on the following: 

1. Facility Capabilities and Procedures. This should include, but not be limited to: 

a. Information on facilities. 

i. Pool type (or housing/pool for pinnipeds) design, description, and dimensions. 

ii. Type of available shelter and/or shading. 

iii. Maximum holding capacity. Description of facility’s maximum holding capacity 

based on minimum standard space requirements and number of animals housed in 

each holding area and the availability of qualified personnel as provided in the 

NMFS document, “Policies and Best Practices: Standards for Rehabilitation 

Facilities”. 

iv. Water Quality. Description of water, source, quality, and how it is maintained, 

including how water is tested and frequency of tests. 

v. How the facility/rehabilitation area is secured from public access. 

vi. Provisions for isolating marine mammals. 

vii. How other wild and/or domestic animals will be kept isolated from marine 

mammals. 

viii. How animals will be quarantined if necessary. 
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

NMFS Evaluation Criteria for a Marine Mammal Stranding Agreement February 2009 

5-2 

b. Information on procedures for: 

i. Food handling and sanitation. 

ii. Human health and safety throughout the rehabilitation facility. 

iii. How medical, husbandry, and other relevant records will be maintained for each 

animal. Samples of record forms are helpful. 

iv. Efforts to reduce disease transmission. 

v. Humane animal care, routine medical procedures, and euthanasia. 

c. Key Personnel. The prospective Participant should have and maintain one Authorized 

Representative and two primary animal care specialists, all with experience in marine 

mammal care and rehabilitation. One of these personnel should fulfill the role of the Animal 

Care Supervisor whom is responsible for overseeing prescribed treatments, maintaining 

hospital equipment, and controlling drug supplies. The person should be adequately trained 

to deal with emergencies until the veterinarian arrives, be able to direct the restraint of the 

animals, be responsible for administration of post-surgical care, and be skilled in maintaining 

appropriate medical records. It is important that the animal care supervisor should 

communicate frequently and directly with the attending veterinarian to ensure that there is a 

timely transfer of accurate information about medical issues. Ideally, this individual should 

be a licensed veterinary technician or an animal health technician who reports to, or is 

responsible to, the attending veterinarian. Additional personnel may be necessary, 

commensurate with the maximum holding capacity. Information regarding key personnel 

should also include: 

i. Overview of staffing plan and capabilities for the rehabilitation facility (e.g., 

veterinarian technicians, food preparation, record keeping, volunteer/shift 

coordination, equipment, pool maintenance, etc.). 

ii. Description of on-site experienced personnel who are caring for the animals, 

including resumes or CVs of all key personnel and documentation of relevant 

training. 

iii. Description of how new personnel and volunteers are trained and monitored. 

iv. Veterinary Support. The prospective Participant should identify an attending 

veterinarian and identify at least one backup veterinarian for when the attending 

veterinarian is not available. Requests should provide documentation of the 

veterinarian’s background, experience, and licensing. 
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

NMFS Evaluation Criteria for a Marine Mammal Stranding Agreement February 2009 

5-3 

2. Contingency Plans. A copy of contingency plans for protecting or relocating marine 

mammals in rehabilitation in case of events such as hurricanes or other natural disasters, 

unusual mortality events, hazardous waste spills, fire, or planned events such as construction. 

3. Copies of all applicable Federal, state, and local permits for rehabilitation facilities. 

4. General plans for release and post-release monitoring of marine mammals in rehabilitation, 

including: 

i. How animals will be assessed for release determinations and who makes the 

assessment. 

ii. How the prospective Participant will follow the NMFS Interim Standards for 

Release of Rehabilitated Marine Mammals (available on the following website: 

http://www.nmfs.noaa.gov/pr/health/eis.htm). 

iii. How prospective Participant will conduct tagging, release, and post-release 

monitoring. 

5. Resources. Sufficient physical and financial resources to maintain appropriate animal care 

for the duration of rehabilitation, including costs associated with release (e.g., long term 

rehabilitation, transport to release site, post release monitoring) or transport to another 

facility. 

5.2 Qualifications for Article V Authorization 

Requests should be evaluated based on the following: 

1. Key personnel should have experience or comparable training in all aspects of marine 

mammal rehabilitation. Requests should address key personnel qualifications for each 

evaluation criteria below: 

a. Experience or education leading to an understanding of the life history, behavior, 

biology, physiology, and animal husbandry of applicable marine mammals. 

b. Familiarity with NMFS Interim Rehabilitation Standards, NMFS Interim Standards for 

Release of Rehabilitated Marine Mammals, and applicable regulations. 

c. Experience in a supervisory role rehabilitating a minimum of three separate rehabilitation 

cases (Note: Multiple animals in rehabilitation from a mass stranding are considered to 

be one case). 

d. Ability to humanely restrain a marine mammal to conduct basic medical procedures such 

as: drawing blood from at least two sites, taking fecal, gastric, blowhole/nasal samples, 

morphometrics, weighing, injections, and tubing. 
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

NMFS Evaluation Criteria for a Marine Mammal Stranding Agreement February 2009 

5-4 

e. Experience maintaining and operating a facility/pool for marine mammal care, including 

familiarity with maintaining proper water quality. 

f. Ability to supervise and coordinate on-site personnel and volunteers. 

g. Ability to conduct necropsies. 

h. Experience with record keeping, such as food intake records, daily behavioral records, 

medical records, and water quality records (e.g., water temperature, salinity, etc.). 

i. Knowledge of how to design and conduct a behavior ethogram (preferred but not 

required). 

2. Attending veterinarians should meet the following criteria: 

a. Have an active veterinary license in the United States (means a person who has 

graduated from a veterinary school accredited by the American Veterinary Medical 

Association Council on Education, or has a certificate issued by the American 

Veterinary Graduates Association's Education Commission for Foreign Veterinary 

Graduates), or has received equivalent formal education as determined by NMFS 

Administrator (adapted from the Animal Welfare Act Regulations 9 CFR Ch. 1). 

b. Assume responsibility for diagnosis, treatment, and medical clearance for release or 

transport of marine mammals in rehabilitation (50 CFR 216.27). 

c. Ability to provide a schedule of veterinary care that includes a review of husbandry 

records, visual and physical examinations of all the marine mammals in rehabilitation, 

and a periodic visual inspection of the facilities and records. 

d. Be available on a 24-hour basis to answer veterinary-related questions, and be 

available in case of an emergency. 

e. Ability to perform routine diagnostic and medical procedures on the type of marine 

mammal most often admitted to the rehabilitation facility (e.g., draw blood, give 

injections, etc). 

f. Have marine mammal experience or be in regular consultation with a veterinarian who 

has marine mammal experience and have access to a list of expert veterinarians to contact 

for assistance.

g. [Reserved. {Have documented one-year clinical experience working with marine 

mammals, or have a written consulting agreement with an experienced marine mammal 

veterinarian, which assures availability of consultation when needed.}] 

h. Ability to conduct full necropsy on marine mammals. 

i. Have access to the most recent edition of the CRC “Handbook of Marine Mammal 

Medicine.” 
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

NMFS Evaluation Criteria for a Marine Mammal Stranding Agreement February 2009 

5-5 

j. Be familiar with and comply with the standards of veterinary care in the NMFS Best 

Practices for Marine Mammal Stranding Response, Rehabilitation, and Release - 

Standards for Rehabilitation Facilities. 

k. Have the appropriate registrations and licenses (e.g., registered with the Drug 

Enforcement Administration for handling controlled substances) to obtain the necessary 

medications for the animals housed at that rehabilitation facility. 

l. Be knowledgeable of species-specific pharmacology. 

m. Have provisions for performance of humane euthanasia. 

n. Ability to write and submit timely disposition recommendations for marine mammals in 

rehabilitation. 

o. Be knowledgeable of marine mammal zoonotic diseases and appropriate safety 

precautions. 

3. A trained volunteer base sufficient to initiate and maintain adequate and appropriate marine 

mammal care and husbandry and implementation of veterinary direction. 

4. Knowledge of national, state, and local laws relating to live animal rehabilitation. 

5. Familiarity with, and a copy of, the most current version of the NMFS Interim Rehabilitation 

Facility Standards and Interim Standards for Release of Marine Mammals. 
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

NMFS Evaluation Criteria for a Marine Mammal Stranding Agreement February 2009 

6-1 

6. Evaluation Criteria for Designee Organizations 

The purpose of a Designee organization is to assist the Participant with sub-region coordination, 

response, and/or rehabilitation capability within the Participant’s geographic area of responsibility 

and under the Participant’s oversight. If a Participant is proposing oversight of a Designee 

organization(s), the Participant [must] should provide evidence that the Designee organization has the 

skills, resources, and organizational capability to respond to dead/live stranded marine mammals [or 

rehabilitate marine mammals]. In some cases, it may not be possible for each proposed Designee 

organization to meet all of the evaluation criteria listed below. If this is the case, NMFS needs 

written assurance and details specifying how the prospective Participant will take responsibility for 

fulfilling specific qualifications lacking for the Designee organization. 

6.1 Information for Designee Organizations for Articles III, IV, 

and V 

1. For each proposed Designee organization, the Participant should provide the same information 

required in sections II through V. 

2. Justification for Designee. The Participant should submit a justification for the geographic 

need, and enhancement of response capabilities provided by the Designee organization to the 

Participant. 

3. Copy of a written and signed Agreement between the Participant and the Designee that 

includes a statement that the Designee organization has read and agreed to the terms of the 

Participants current Stranding Agreement. 

6.2 Qualifications for Designee Organizations for Articles III, IV, 

and V 

1. Each proposed Designee organization will be evaluated according to the same required 

qualifications listed in sections II through V. 
THIS PAGE INTENTIONALLY LEFT BLANK 
FINAL 

POLICIES AND BEST PRACTICES

MARINE MAMMAL STRANDING RESPONSE, 

REHABILITATION, AND RELEASE

STANDARDS FOR REHABILITATION FACILITIES 

Prepared by 

Laurie Gage, D.V.M., Dipl. ACZM 

USDA Animal and Plant Health Inspection Service 

Animal Care

Edited by 

Janet E. Whaley, D.V.M. February 2009 

NOAA National Marine Fisheries Service 

Marine Mammal Health and Stranding Response Program 

1315 East-Highway 

Silver Spring, Maryland 20910
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Rehabilitation Facilities February 2009 

i 

Standards for Rehabilitation Facilities 

Table of Contents 

1. STANDARDS FOR CETACEAN REHABILITATION FACILITIES....................................... 1-1

1.1 Facilities, Housing, and Space.........................................................................................1-1

1.1.1 Space Requirements for Pool, Bay, or Ocean Pens ............................................1-2

1.1.2 Pool or Pen Design .............................................................................................1-3

1.1.3 Shelter, Shading, and Lighting ...........................................................................1-4

1.1.4 Critical Care Animals and Calves.......................................................................1-5

1.1.5 Number of Animals Housed in Each Pool/Pen...................................................1-6 

1.1.6 Housekeeping .....................................................................................................1-7

1.1.7 Pest Control ........................................................................................................1-7

1.1.8 Security for Facility ............................................................................................1-8

1.2 Water Quality...................................................................................................................1-8

1.2.1 Source and Disposal of Water ..........................................................................1-10

1.3 Water Quality Testing....................................................................................................1-10

1.3.1 Water Quality Tests ..........................................................................................1-11

1.3.2 Frequency of Testing in Closed, Semi-Open, or Open Systems.......................1-12

1.3.3 Chemical Additives...........................................................................................1-12

1.3.4 Water Circulation..............................................................................................1-13

1.3.5 Salinity..............................................................................................................1-13

1.3.6 pH .....................................................................................................................1-14

1.3.7 Water Temperature ...........................................................................................1-14

1.4 Quarantine......................................................................................................................1-15

1.4.1 Prevention of Animal to Animal Transmission of Diseases .............................1-15

1.4.2 Prevention of Domestic Animal to Marine Mammal Transmission of Disease1-16

1.4.3 Prevention of Wild Animal to Marine Mammal Transmission of Disease.......1-17

1.4.4 Prevention of Marine Mammal to Domestic Animal Transmission of Disease1-17

1.4.5 Prevention of Stranded Marine Mammal to Captive Marine Mammal 

Transmission of Disease ...................................................................................1-17

1.4.6 Methods to Reduce Spread of Disease from Animals Housed in Open Sea/Bay 

Pen Systems ......................................................................................................1-18

1.4.7 Evaluation Requirements Before Placing Marine Mammals Together ............1-18

1.4.8 Zoonotic Considerations...................................................................................1-19

1.4.9 Pre-Release Guidelines.....................................................................................1-19

1.5 Sanitation .......................................................................................................................1-20

1.5.1 Primary Enclosure Sanitation ...........................................................................1-20

1.5.2 Sanitation of Food Preparation Areas and Food Receptacles ...........................1-20

1.6 Food, Handling, and Preparation ...................................................................................1-21

1.6.1 Diets and Food Preparation...............................................................................1-21

1.6.2 Food Storage and Thawing...............................................................................1-21

1.6.3 Supplements......................................................................................................1-22

1.6.4 Feeding .............................................................................................................1-23

1.6.5 Public Feeding ..................................................................................................1-23

1.6.6 Feed Records ....................................................................................................1-23

1.7 Veterinary Medical Care................................................................................................1-23

1.7.1 Veterinary Experience ......................................................................................1-24

1.7.2 Veterinary Program...........................................................................................1-25
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Rehabilitation Facilities February 2009 

ii 

1.8 Laboratory Tests and Frequency of Testing ..................................................................1-26

1.8.1 Laboratory Testing............................................................................................1-27

1.9 Record Keeping and Data Collection ............................................................................1-28

1.9.1 Record Keeping ................................................................................................1-28

1.9.2 Data Collection .................................................................................................1-30

1.10 Euthanasia Protocols......................................................................................................1-30

1.11 Health and Safety Plans for Personnel...........................................................................1-31

1.12 Contingency Plans .........................................................................................................1-31

1.13 Viewing..........................................................................................................................1-32

1.14 Training and Deconditioning Behaviors........................................................................1-32

2. STANDARDS FOR PINNIPED REHABILITATION FACILITIES ......................................... 2-1

2.1 Facilities, Housing, and Space.........................................................................................2-1

2.1.1 Pool Requirements..............................................................................................2-2

2.1.2 Dry Resting Area ................................................................................................2-3

2.1.3 Pool or Pen Design .............................................................................................2-3

2.1.4 Length of Stay and How it Affects Space...........................................................2-4

2.1.5 Shelter, Shading, and Lighting ...........................................................................2-4

2.1.6 Air Temperature..................................................................................................2-5

2.1.7 Housing for Critical Care Animals .....................................................................2-5

2.1.8 Housing of Pups..................................................................................................2-6

2.1.9 Housing of Older Pups........................................................................................2-7

2.1.10 Number of Animals Housed in Each Pen/Pool...................................................2-7

2.1.11 Housekeeping .....................................................................................................2-8

2.1.12 Pest Control ........................................................................................................2-8

2.1.13 Security for Facility ............................................................................................2-9

2.2 Water Quality...................................................................................................................2-9

2.2.1 Water Source and Disposal...............................................................................2-11

2.3 Water Quality Testing....................................................................................................2-11

2.3.1 Water Quality Tests ..........................................................................................2-12

2.3.2 Frequency of Testing in Closed, Semi-open, or Open Systems........................2-13

2.3.3 Chemical Additives...........................................................................................2-13

2.3.4 Water Circulation..............................................................................................2-14

2.3.5 Salinity..............................................................................................................2-14

2.3.6 pH .....................................................................................................................2-14

2.3.7 Water Temperature ...........................................................................................2-15

2.4 Quarantine......................................................................................................................2-15

2.4.1 Prevention of Animal to Animal Transmission of Diseases .............................2-16

2.4.2 Prevention of Domestic Animal to Marine Mammal Transmission of Disease2-17

2.4.3 Prevention of Wild Animal to Marine Mammal Transmission of Disease.......2-17

2.4.4 Prevention of Marine Mammal to Domestic Animal Transmission of Disease2-17

2.4.5 Prevention of Stranded Marine Mammal to Captive Marine Mammal 

Transmission of Disease ...................................................................................2-17

2.4.6 Methods to Reduce Spread of Disease from Animals Housed in Open Sea/Bay 

Pen Systems ......................................................................................................2-18

2.4.7 Evaluation Requirements before Placing Marine Mammals Together.............2-19

2.4.8 Zoonotic Considerations...................................................................................2-19

2.4.9 Pre-Release Guidelines.....................................................................................2-19

2.5 Sanitation .......................................................................................................................2-20

2.5.1 Primary Enclosure Sanitation ...........................................................................2-20
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Rehabilitation Facilities February 2009 

iii 

2.5.2 Sanitation of Food Preparation Areas and Food Receptacles ...........................2-20

2.6 Food, Handling, and Preparation ...................................................................................2-21

2.6.1 Diets and Food Preparation...............................................................................2-21

2.6.2 Food Storage and Thawing...............................................................................2-21

2.6.3 Supplements......................................................................................................2-23

2.6.4 Feeding .............................................................................................................2-23

2.6.5 Public Feeding ..................................................................................................2-23

2.6.6 Feed Records ....................................................................................................2-23

2.7 Veterinary Medical Care................................................................................................2-24

2.7.1 Veterinary Experience ......................................................................................2-24

2.7.2 Veterinary Program...........................................................................................2-25

2.8 Laboratory Tests and Frequency of Testing ..................................................................2-26

2.9 Record Keeping and Data Collection ............................................................................2-28

2.9.1 Record Keeping ................................................................................................2-29

2.9.2 Data Collection .................................................................................................2-30

2.10 Euthanasia......................................................................................................................2-30

2.11 Health and Safety for Personnel ....................................................................................2-31

2.12 Contingency Plans .........................................................................................................2-31

2.13 Viewing..........................................................................................................................2-31

2.14 Training and Deconditioning Behaviors........................................................................2-32

2.15 References......................................................................................................................2-32

3. FREQUENTLY ASKED QUESTIONS................................................................................ 3-1
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Rehabilitation Facilities February 2009 

iv 

Introduction 

As part of the National Marine Fisheries Service (NMFS) Stranding Agreements, the Agency will 

require that all rehabilitation facilities meet the Minimum Standards presented in this document. The 

goal of this document is to set MINIMUM facility, husbandry, and veterinary standards for 

rehabilitating marine mammals in order to meet the prescribed NMFS Best Practices Marine Mammal 

Stranding Response, Rehabilitation, and Release - Standards for Release. Likewise some of the 

standards put forth in this document are based on the U.S. Department of Agriculture (USDA), 

Animal and Plant Health Inspection Service (APHIS) Animal Welfare Act (AWA) regulations which 

define minimum standards for permanent captive marine mammals. However, there are some 

differences between the two documents in that these standards were developed for temporary care and 

all age groups. RECOMMENDED Standards are included in some sections, and consist of facility 

design and operational suggestions for optimizing the rehabilitation success rate. Meeting or 

exceeding the recommended standards may be considered a goal to strive towards when upgrading 

existing, or designing new facilities or protocols. 

It is the intent of NMFS to provide a reasonable process for facilities to be upgraded to meet the 

minimum standards set forth in this document. Substandard facilities may be improved using funds 

that may be available through the John H. Prescott Rescue Assistance Grant Program (Prescott 

Grant). Likewise Prescott Grant funds may also be used to improve facilities that meet minimum 

standards with the goal to achieve or exceed the recommended standards. 

Health and safety practices are highly stressed in this document. NMFS expects that all personnel 

and volunteers to be trained to the HIGHEST LEVEL of responsibility they are assigned. 

Rehabilitation facilities are encouraged to comply with Occupational Safety and Health 

Administration regulations. 

Purpose 

The purpose of rehabilitation is to provide humane care for stranded marine mammals and to optimize 

the success of releasing the animals back to the wild. Defining a successful release encompasses 

many factors. As mandated by Title IV Section 402 (a) of the Marine Mammal Protection Act, 

NMFS has developed guidance and criteria for release based on optimizing the chances for survival 

and minimizing the risk to wild populations (NMFS/FWS BEST PRACTICES for Marine Mammal 

Stranding Response, Rehabilitation, and Release – Standards for Release ). These facility standards 

have been developed to achieve the goals set forth by the Standards for Release. 
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This document is organized by taxa similar to the Standards for Release. While many aspects of 

rehabilitating cetaceans and pinnipeds that are the same, there are likewise many significant 

differences. Water quality, pool space and design, and handling debilitated animals are examples of 

the bigger differences between facility design and equipment required for rehabilitation of these 

animals. Rehabilitation of cetaceans requires more expensive facilities, as there must be larger, 

deeper pools available, salt water systems, and more elaborate filtration in closed system situations. 

While some facilities have adequate equipment and personnel to rehabilitate pinnipeds, they may not 

meet the standards required for the rehabilitation of cetaceans. Having two sets of guidelines allows 

NMFS the flexibility of issuing agreements specific to the types of animals that may be rehabilitated 

at each facility. 
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1. Standards for Cetacean Rehabilitation Facilities 

1.1 Facilities, Housing, and Space 

Pools for stranded cetaceans must be appropriate for the basic needs of the animal including keeping 

the skin moist, to providing buoyancy, and aiding thermoregulation. Debilitated cetaceans often 

cannot swim and may require assistance when first introduced to a rehabilitation pool. Cetaceans 

arriving in a debilitated condition may have needs requiring smaller pools than those that are able to 

swim and dive upon arrival. Choice of pool size may be important and is case specific. Although 

chances of survival may be improved if animals capable of swimming are given larger space, deeper 

pools may make it more difficult and stressful to catch an animal for feeding, hydration, and 

treatment. Likewise with multiple strandings, grouping animals by size, ability to swim, species, and 

health status may improve overall survival rates. Placing the larger, more robust animals in separate 

pools or swimming areas away from the smaller, less dominant and/or more debilitated animals may 

enhance the success of the rehabilitation efforts for the weaker animals. Species of cetaceans known 

to be social in nature should be housed with other compatible species. Social compatibility should be 

considered an important part of appropriate housing. Animals should be closely monitored when 

introduced to a pool and carefully evaluated for social compatibility. 

It is up to the attending veterinarian, as defined in Section 1.7, and experienced rehabilitation staff, to 

decide how to house the animal most appropriately based on their observations and physical 

examination. 

Each animal admitted to a rehabilitation center should be placed in a quarantine holding area and 

have a full health evaluation performed by the attending veterinarian. Sufficient quarantine time 

should be allowed for results from tests and cultures to be evaluated before the animal is placed with 

animals that are apparently disease free. Cetaceans with evidence of infectious disease must be 

quarantined (See Section 1.4 Quarantine).

During multiple or unusual stranding situations such as hazardous waste spills, catastrophic weather 

events, toxic algal blooms, or other events leading to unusually high morbidity, rehabilitation center 

personnel may need to adjust the number of animals that would be normally housed in each pool, bay 

or ocean pen. The attending veterinarian is responsible for assuring that the number of animals 

housed in one pool or pen will be appropriate based on the situation. The number of animals housed 

should be determined not only by the amount of pool space and size of the animals, but also by the 

number of qualified personnel available on a per animal basis. The recommended number of 
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personnel to animals less than 250 kg is 3:1 for critical care cetaceans; 2: 1 - 4 once stabilized, and 

1:4 when animals are eating regularly and no longer require regular handing. Larger critical care 

cetaceans will require more personnel per animal. 

Unweaned neonate cetaceans shall not be admitted for rehabilitation without prior approval of NMFS. 

Unweaned cetaceans, once rehabilitated, are frequently not suitable for release or require stringent 

release criteria to ensure humane treatment and a successful outcome. A rehabilitation facility needs 

to thoughtfully consider these types of cases when developing overall facility goals and objectives. 

If the facility aims to rehabilitate neonatal and/or unweaned calves, then they need to discuss and seek 

concurrence with NMFS options for final disposition since most of these cases will be nonreleasable. 

These issues need to be researched, outlined and NMFS approved prior to admitting any cases. The 

plan should include options and criteria for release if appropriate (e.g., release with mother), 

considerations for permanent care, and euthanasia. 

NMFS Regulation, U.S.C. 50 CFR 216.27(c)(5) states that marine mammals undergoing 

rehabilitation shall not be subject to public display. The definition of public display under U.S.C. 50 

CFR “is an activity that provides opportunity for the public to view living marine mammals at a 

facility holding marine mammals captive.” (See Section 1.13 Viewing). 

1.1.1 Space Requirements for Pool, Bay, or Ocean Pens 

MINIMUM STANDARD 

• All pools or pens must be deep enough for animal(s) to float and submerge and shall be available 

for all rehabilitating cetaceans. The diameter and depth of the pool for critical care animals is at 

the discretion of the attending veterinarian. 

• Pool depth for non-critical animals (animals able to swim unassisted) must equal one-half the 

body length or 0.9 meters (3 feet), whichever is greater. 

• Pools shall have a minimum horizontal dimension (MHD) of 7.3 meters (24 feet) or two times the 

actual length of the largest species housed in the pool, whichever is greater. 

• Animals housed longer than 6 months must be provided with pools at least 1.5 meters (5 feet) 

deep and must meet the USDA, APHIS AWA MHD standards unless otherwise directed by the 

attending veterinarian. This should be documented and justified with a signed veterinary 

statement in the medical records. 
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RECOMMENDED 

• Pools shall have a depth equal to the body length or 1.8 meters (6 feet), whichever is greater. 

• Pools shall have a minimum horizontal dimension of 9.0 meters (30 feet) or two times the 

average adult length of the largest species in the pool, whichever is greater. 

1.1.2 Pool or Pen Design 

Pools or pens designed to maximize the ease of handling, and to limit the amount of time the cetacean 

spends out of water for husbandry or veterinary procedures may help to decrease the stress of 

handling. Pools designed with a deep and a shallow end work well because the cetaceans may stay in 

the deep end while the pool level is dropped. The animal requiring treatment may be moved to the 

shallow end and immediately placed back in the deep end when the treatment has been completed. 

Pools equipped with a false bottom that can be lifted are ideal because the animal can be caught 

quickly without dropping the level of the pool water and the animal may be immediately returned to 

the pool once treatments have been completed. False bottoms in bay or ocean pens will facilitate 

capture, since there is no convenient way to drop the water level in those situations. Pools equipped 

with lift-bottoms and/or multi-level pools are recommended, however lift bottoms must be carefully 

designed when being retrofitted to existing pools. 

Scoop-net or trampoline methods may also be used for capture, where a net is placed on the pool or 

pen bottom under the swimming animal and it is lifted by multiple personnel using tag lines. While 

this method is an inexpensive alternative to a false floor it may not be suitable for multiple or large 

animals. 

New rehabilitation pools should be designed and constructed to minimize introduction of 

anthropogenic noise from life-support equipment or other sources. This can be accomplished through 

sloping of walls, insulation with soil or other materials around the sides of the pool and/or through 

isolation of noise-generating equipment. Existing pools that do not meet these specifications may be 

allowed, or a retrofit may be requested if the pools are substandard to the point of becoming an 

animal welfare issue. 

MINIMUM STANDARD 

• Any shape pool that meets minimum space standard 

• Construction materials 

o Open water pens shall optimally be constructed of plastic or other rigid netting. 
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o If cotton or nylon netting material is used it must be small enough gage to prevent 

entanglement. 

RECOMMENDED 

• Pools with long axes that provide relief from constant turning while swimming 

• Pools designed to promote good water circulation and to minimize anthropogenic noise. 

• Single depth pool with false bottom that can be lifted 

 OR 

• Pool with a sloping bottom where the water level may be dropped in the shallow end to facilitate 

treatment 

 OR 

• Single or multi-depth pool with an adjoining “med pool’ with a false bottom that can be lifted 

 OR 

• Ability to drop a pool in less than 2 hours and refill it to a “swimming level” in less than 30 

minutes 

1.1.3 Shelter, Shading, and Lighting

Rehabilitation facilities located where there is inclement weather need to provide shelter to 

rehabilitating animals that may be exposed to extreme heat or cold. Cetaceans held in rehabilitation 

facilities may not have normal activity levels and thin animals may be unable to thermoregulate 

properly. These animals may require shade structures to protect them from direct sunlight and 

extreme heat, or shelter to protect them from extreme cold. 

Animals held in indoor facilities should be provided with appropriate light and dark photoperiods 

which mimic actual seasonal conditions. Light provided in indoor facilities shall be of sufficient 

intensity to clearly illuminate the pool. 

MINIMUM STANDARD 

• Shade structures or shelters must be provided to animals when local climatic conditions could 

compromise the health of the animal noting that some cetaceans undergoing rehabilitation may be 

unable to swim, dive, or thermoregulate, thus requiring either shelter from the elements or shade. 

• Shade structures, where necessary, shall be large enough to provide shade to at least 50% of the 

MHD surface area determined for the species held in the pool. MHD is defined as 7.3 meters (24 

feet) or two times the actual length of the largest species housed in the pool, whichever is greater. 
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• Lighting should be appropriate for the species. 

RECOMMENDED 

• Full spectrum lights or a natural source of lighting for animals housed indoors. 

• Removable or adjustable shade structures in pens that are easily cleaned and that provide more 

 natural sunlight to animals that are swimming and diving normally. 

1.1.4 Critical Care Animals and Calves 

Debilitated and ill cetaceans are often sedentary and tend to float at the surface for long periods of 

time. Some are unable to swim and dive. Some may require support in order to stay afloat enough to 

breathe regularly. Young calves may be weak and require assistance. Support may be provided by 

floatation devices attached to the animal or rehabilitation personnel supporting the animal utilizing a 

variety of methods. A shallow area that allows the animal to rest on the bottom while keeping its 

blowhole above the surface may also suffice. This shallow resting shelf must be of sufficient depth 

for larger animals (over 50 kg) to provide adequate buoyancy to prevent organ-crushing. Small 

cetaceans may also be supported in a stretcher that is hung within an open aluminum frame while 

maintaining the water depth at the midline of the animal. These animals must be protected from sunrelated skin damage by providing them with shade or covering their exposed skin with an appropriate, 

non-desiccating sun block that allows proper thermoregulation. Exposed skin may be protected from 

desiccation with the use of emollients applied to the skin or a water spray. 

MINIMUM STANDARD 

• Ensure support is available via floatation devices, a shallow resting shelf, sloping beach, 

suspended stretcher system, or other support for critically ill or neonatal cetaceans that are weak 

and/or cannot swim normally. 

• Monitor animals requiring support. 

• Provide sufficient shade. 

• Provide a water spray or method for keeping skin moist for cetaceans that cannot swim or dive. 

• Control air temperature above the pool to facilitate recovery, protect rehabilitating animals from 

heat or cold extremes, and prevent discomfort. This may be achieved by heating or cooling the 

water appropriately for the species and condition of the animal and/or providing shelter from the 

elements. 
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1.1.5 Number of Animals Housed in Each Pool/Pen 

During multiple or unusual mortality event (UME) strandings the number of cetaceans received by 

the facility is limited not only by the number and size of the holding pools or pens, but the number of 

qualified trained rehabilitation staff members available to care for the animals. Due to the intensive 

24 hour assistance required for critical care cetaceans, a minimum of two qualified trained staff 

members are necessary for each and every dependent cetacean on the premises. The maximum 

number of animals maintained in each pool and onsite at the facility shall be determined by the 

attending veterinarian and dictated by the number of qualified staff available to care for the animals. 

MINIMUM STANDARD 

• Provide enough pool space for each animal to swim, dive, and maintain an individual distance of 

one body length from other animals housed in the same pool.

• Provide 2 qualified trained rehabilitation staff members for every critical care or dependent 

cetacean weighing less than 250 kg. Larger critical care cetaceans will require more personnel to 

handle each animal.

• Staff must be available on a 24-hour basis for critical animal care.

• Provide one trained staff member for every 3-4 cetaceans undergoing less critical periods of 

rehabilitation; during reconditioning or during counter-conditioning if training or desensitization 

was used for feeding stations, medical procedure desensitization or transport approximations.

• Provide one trained staff member for every five cetaceans that are eating regularly and do not 

require handling.

RECOMMENDED 

• Provide enough pools or pool space to house multiple animals in accordance with the calculated 

space outlined in the APHIS AWA standards for captive cetaceans. 

• Provide three qualified trained rehabilitation staff members for every critical care or dependent 

cetacean. 

• Provide two trained staff members for every 1 – 4 cetaceans undergoing less critical periods of 

rehabilitation; during reconditioning; or prior to reintroduction. 
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1.1.6 Housekeeping 

MINIMUM STANDARD 

• Keep support buildings and grounds as well as areas surrounding rehabilitation pools clean and in 

good repair. 

• Maintain perimeter fences in good repair, and ensure they are an adequate height and construction 

to keep people, animals, and pests out. 

• Ensure primary enclosures housing marine mammals do not have any loose objects, sharp 

projections, and/or edges which may cause injury or trauma to the marine mammals contained 

therein. 

• Objects introduced as environmental enrichment must be too large to swallow and made of non 

porous cleanable material that is able to be disinfected. Likewise items such as rub ropes shall be 

secured to prevent entanglement. 

• All drains and overflows must have screened covers. 

• Ensure there are no holes or gaps larger than 1⁄2 the size of the head diameter of the calf of the 

smallest species to be housed. 

RECOMMENDED 

• Coat all pool and haul-out surfaces with a non-porous, non-toxic, non-degradable cleanable 

material that is able to be disinfected. 

1.1.7 Pest Control 

MINIMUM STANDARD 

• Establish and maintain a safe and effective program for the control of insects, avian and 

mammalian pests. This should include physical barriers to prevent feral and/or wild animals from 

contact with the rehabilitating animals. 

• Insecticides or other such chemical agents shall not be applied in a primary enclosure housing 

marine mammals or a food preparation area except as authorized in writing by the attending 

veterinarian. 

• If applied, all appropriate measures must be taken to prevent direct contact with the 

insecticide/pesticide, whether airborne or waterborne, by the animal. 
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1.1.8 Security for Facility 

Stranded marine mammals often attract public attention and must be protected from excessive 

commotion and public contact. Ensuring a quiet stress-free environment for rehabilitating animals 

may improve their chance to recover and survive. Public viewing of marine mammals is discussed in 

Section 1.13 of this document. 

MINIMUM STANDARD 

• Locate rehabilitation facilities at sites that have the ability to be secured from the public. 

• Prevent direct public contact with the rehabilitating animals but utilizing appropriate fencing, 

staff and security personnel. 

RECOMMENDED 

• Maintain 24- hour monitoring when animals are present or maintain a secure perimeter fence with 

the ability to lock the area off to the public when staff is not present. 

1.2 Water Quality 

Water quality is an essential part of keeping cetaceans healthy. Sick or debilitated cetaceans should 

be housed in pools filled with clean, appropriately treated saltwater to facilitate their recovery. 

There are four basic types of water systems: 

• Pools with filtration systems (closed systems) 

• Pools without filtration systems (dump and fill systems) 

• Pools with periodic influx of natural seawater (semi-open systems) 

• Open water systems (flow-through pools, bay or sea pens) 

There are a number of variables which will affect water quality. The number and size of cetaceans 

utilizing each pool will vary throughout the year at most rehabilitation facilities. During unusual 

stranding events the number of cetaceans utilizing one pool may increase dramatically, creating a 

heavier load of waste which must be handled by the filtration system in closed systems and by the 

amount of water flow-through in semi-open and open systems. 

Filtration or life support systems are essential to maintaining clean water for animals held in closed or 

semi-closed systems. Life support systems have three basic parts; mechanical filters that remove 

solids, biological filters or baffles to remove or detoxify chemicals in the water, and disinfecting 
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methods to control or remove pathogens. In addition to maintaining clean water in the animal pools, 

these systems may be needed to treat waste water, depending on waste water disposal requirements. 

If a temporary increase in waste production overwhelms part or all of the life support system, a good 

water quality control program will require alternative options. 

The source of water used in closed systems generally is fresh water obtained from municipal sources 

whereas water in open and semi-open systems comes from a bay or sea source. Municipal fresh water 

must have salt added to increase the salinity to appropriate levels to maintain cetaceans. Water in 

closed systems must be regularly filtered through sand and gravel filters to remove particulate matter, 

and disinfectants such as chlorine or bromine are added at appropriate levels to eliminate pathogens. 

More elaborate systems utilize ozone to oxidize pathogens in the water. The source should be 

independent of other rehabilitation and captive animal areas. 

Factors that affect water quality are: 

• Size of pool or pen 

• Efficiency of filtration system or water flow-through rate (tides) 

• Water turnover rate 

• Number, size and species of animals housed in pool or pen 

• Nature and amount of food consumed by animals in pool or pen 

• Nature of bottom substrate 

• Frequency of cleaning the pool 

• Types, amounts, and the frequency with which chemicals are added to the system 

• Temperature of the water 

• Pathogens in the water 

• Biotoxins in open water pens or in pools where the source water comes from the ocean or bay 

• Contaminants (oil, pesticides, etc.) in open water pens 

• Hazardous waste spills 

• Inclement weather 

• Sunlight contributing to algae production on pool surfaces, which in turn can support bacteria. 
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1.2.1 Source and Disposal of Water 

The water source for cetaceans housed in closed or semi-closed systems may be municipal water, 

well water, or water brought into the facility from an adjacent body of water or estuary. The source 

should be independent of other rehabilitation and captive animal areas. 

MINIMUM STANDARD 

• Salt water must be readily available to fill pools housing rehabilitating cetaceans unless otherwise 

directed by the attending veterinarian. 

• Fresh water must be available to clean and wash down surrounding areas. 

• For pools without adequate filtration systems, drain water from pools daily or as often as 

necessary to keep the pool water quality within acceptable limits. 

• Discharge wastewater in accordance with state or local regulations. Facility managers must seek 

appropriate authorization to dispose of waste water. Documents of authorization or necessary 

permits must be kept on site as part of the administrative record and may be requested by NMFS 

as part of the NMFS Stranding Agreement. 

• Chemicals, when necessary, shall be added in appropriate amounts to disinfect the water or adjust 

the pH, but not added in a manner that could cause harm or discomfort to the animals. 

• Have contingency protocols describing how water quality will be maintained during periods of 

peak animal use. 

RECOMMENDED 

• Enough salt water must be available to completely fill pools within two hours of draining. 

• Maintain a filtration system designed to optimize water quality in each holding pool and decrease 

water waste. 

1.3 Water Quality Testing 

It is important to test the water in which the animals live on a regular basis. Coliform bacterial counts 

are used to monitor the efficiency of the filtration system to eliminate potentially harmful bacteria. 

Coliform counts should be done at least once per week and more frequently if there are very large or 

multiple animals utilizing the pool. While coliform numbers may be described as Most Probable 

Number (MPN) per 100 ml, a more accurate method of measuring coliforms is to determine the total 

coliform count, or the fecal coliform count. 
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Temperature of the water is especially important if the animal lacks the ability to thermoregulate. 

Water may require heating or chilling to aid debilitated animals in their ability to maintain optimal 

body temperature. Water temperature regulation is not feasible in open water pens, but keeping track 

of the water temperature in sea pens may aid the staff in making husbandry decisions. 

If coliform counts or the water temperature become too high in any system, measures must be taken 

to correct the problem in a timely manner. A partial-to-total water change may be necessary to correct 

the problem in a closed or semi-closed system. If the coliform counts are considered too high in sea or 

bay pens, efforts should be made to circulate clean sea water through the pens using pumps, paddles 

or other methods of moving water. 

Chemicals added to the water may damage eyes and skin, therefore levels must be monitored daily. 

Emergency chemicals should be on hand such as sodium thiosulfate in case of the accidental 

hyperchlorination of a system. Salinity may also have an impact on the health of the skin and eyes, as 

well as the comfort level of the animal, and should be monitored regularly. 

1.3.1 Water Quality Tests 

MINIMUM STANDARD 

• Measure coliform growth weekly. 

• Total coliform counts must not exceed 500 per 100 ml or a MPN of 1000 coliform bacteria per 

100 ml water. Fecal coliform counts are not to exceed 400 per 100 ml. 

• If the above tests yield results that exceed the allowable bacterial count, then two subsequent 

samples must be taken to repeat the test(s) where the level(s) is/are exceeded. The second sample 

is to be taken immediately after the initial test result, while the third sample would be taken 

within 48 hours of the initial test. 

• If the averaged value of the three test results still exceeds the allowable bacterial counts, the 

condition must be corrected immediately or the animals must be moved to a contingency facility. 

• Maintain pH between 6.5 and 8.5. 

• Maintain salinity between 24 - 35 ppt. 

• Maintain the temperature of the water so that it falls within parameters appropriate for the 

species. 

• Measure oxidant levels in systems which require use of a chemical disinfectant and/or ozone in 

the system (for closed systems). 
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RECOMMENDED 

• Maintain pH between 7.2 and 8.2. 

• Total Coliforms with blanks and controls, fecal Coliform, fecal Strep, and yeast count performed 

at least weekly. 

1.3.2 Frequency of Testing in Closed, Semi-Open, or Open Systems 

MINIMUM STANDARD 

• Measure water temperature, pH, salinity, chemical additives (if applicable) daily in all pools. 

• Measure coliform counts weekly; and more frequently at the discretion of the attending 

veterinarian. 

RECOMMENDED 

• If ozone systems are used, measure ozone levels regularly in the animal pools. Ozone levels shall 

not exceed 0.02 mg/liter. 

• Test source and discharge water at least once per day or more frequently for “flow through” 

systems. 

• Maintain records for tests with time, level and results – reviewed and signed monthly by the 

attending veterinarian or the animal care supervisor. 

1.3.3 Chemical Additives

Total chlorine = Free chlorine + Combined chlorine. 

MINIMUM STANDARD 

• Maintain total chlorine below 1.5 ppm, where the combined chlorine shall not exceed 50% of the 

total chlorine 

• All additives must be recorded 

• pH may be adjusted chemically – for example – pH may be raised with sodium carbonate, or soda 

ash; or lowered with HCl or CO2; but not added in a manner that could cause harm or discomfort 

to the animals. 

• Maintain Material Safety Data Sheet (MSDS) information and signage as well as appropriate 

handling equipment for the addition of chemicals. 
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1.3.4 Water Circulation 

The amount of water turnover through the filtration system in a closed or semi-open system is 

important to maintain water quality by removing organic waste and particulate matter. Likewise the 

amount of water movement through an open water pen is also important in the maintenance of water 

quality. Generally, adequate tidal action will result in the equivalent of two complete water changes 

per day. 

MINIMUM STANDARD 

• Maintain sufficient turnover of water through the filtration system in closed or semi-open systems 

to keep the water quality at or above acceptable limits, with a minimum of two complete water 

changes per day. 

• Ensure methods for moving water (water paddles, pumps, spray devices) are available to aerate 

and move water in open water pens with insufficient flow of tides or water through the 

enclosures. These methods should be sufficient to provide the equivalent of two water changes 

per day. 

RECOMMENDED 

• A minimum full water turnover rate of every four hours for each pool in closed or semi-open 

systems. 

1.3.5 Salinity 

Acceptable salinity levels are dependant on the species and condition of the cetacean and the 

duration of the stay. Most species of cetaceans require a salinity level greater than 24 ppt in order to 

maintain healthy skin and eyes. Occasionally the attending veterinarian may chose to house the 

cetacean in fresh or nearly fresh water for a period not exceeding 3 days. Reasons for maintaining 

cetaceans in fresh or brackish water should be noted in the veterinary record and signed by the 

veterinarian. Some species of cetacean are better adapted to live in brackish water and may do well in 

lower salinity levels than other species. 

MINIMUM STANDARD 

• Maintain salinity levels over 24 ppt unless a written veterinary plan calls for lower salinity levels, 

or if the animals are housed in sea pens nearby their resident range. 
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RECOMMENDED 

• Ideal salinity levels should approach natural ocean salinity levels (30 – 33 ppt) but acceptable 

industry standards suggest maintaining cetaceans in water with salinity levels over 24 ppt. 

1.3.6 pH 

MINIMUM STANDARD 

• Maintain pH in a range between 6.5 to 8.5. 

RECOMMENDED 

• Maintain pH between 7.2 –8.2. 

1.3.7 Water Temperature 

Many species of cetaceans are adapted to maintain normal body temperatures when living in a broad 

range of water temperatures. Healthy Tursiops have been housed successfully in water ranging from 

50o

 to 80o F. Atlantic white-sided dolphins fail to thrive in water over 80o F and North Atlantic harbor 

porpoise do best in 45 to 65o F. Some warmer water species, such as a Vaquita, will require 

consistent warm water environments. It is therefore important to know if the species being 

rehabilitated comes from a polar, temperate or tropical climate. It is of equal importance to know the 

temperature range of water in their primary habitat. Young, underweight, and debilitated animals 

may also require warmer water than found in their primary habitat. 

Cetaceans such as bottlenose dolphins adjust their blubber thickness seasonally in response to water 

temperature. This must be considered when readying rehabilitated animals for release. Therefore 

animals should be acclimated to an appropriate seasonal water temperature prior to release. 

MINIMUM STANDARD 

• Hold water temperatures within the normal seasonal habitat temperature range for the species 

under rehabilitation unless otherwise authorized by the attending veterinarian in writing. 

• Provide methods to heat and maintain warm water environments for species that require it, or for 

debilitated individuals that are incapable of maintaining appropriate body temperature. 

• Monitor the temperature of water being heated or cooled. 

• Design water systems to minimize the chance of rehabilitating cetaceans from becoming 

hyperthermic or hypothermic. 
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RECOMMENDED 

• Monitor blubber thickness ultrasonically. 

1.4 Quarantine 

Cetaceans brought to a rehabilitation facility have no medical history and may carry diseases 

communicable to other marine mammals, other animals, or humans. Likewise, these animals are often 

debilitated and may suffer from a variety of illnesses which may compromise their immune systems 

making them susceptible to diseases from other animals and/or the rehabilitation environment. 

Quarantine areas must be available and proper biosecurity protocols must be in place for all incoming 

animals at rehabilitation facilities. 

Direct contact between the general public and cetaceans undergoing rehabilitation should be avoided 

because of the zoonotic risk from pathogens carried by marine mammals. There have been 

documented cases of Brucella, Erysipelothrix, and Blastomyces being passed from cetaceans to 

humans. 

Listed on the following website are numerous other potentially zoonotic marine mammal pathogens 

(see http://www.vetmed.ucdavis.edu/whc/mmz/). See also: 2004 UC Davis Wildlife Health Center 

Report for the Marine Mammal Commission – Assessment of the Risk of Zoonotic Disease 

Transmission to Marine Mammal Workers and the Public: Survey of Occupational Risks.

MINIMUM STANDARD 

Maintain sufficient quarantine facilities and space for appropriate quarantine of incoming animals or 

for holding animals with contagious diseases. 

1.4.1 Prevention of Animal to Animal Transmission of Diseases 

• Quarantine all new animals in a separate dedicated quarantine area and provide pools that can be 

isolated with the use of dividers, tarps, or physical space from the rest of the animal housing 

areas. 

• Have separate filtration and water flow systems for pools in quarantine/isolation areas. 

• Use dedicated protective clothing for personnel. 

• Use foot baths, glove baths, and methods to disinfect clothing, wet suits, or exposure suits 

between handling animals within quarantine area and outside of quarantine area. 

• Maintain equipment and tools strictly dedicated to the quarantine areas. 
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• Provide dividers between pens and pools that prevent washdown or splash from moving from one 

pool to another. 

• Provide sufficient space; ideally greater than 20 feet or 6 meters; or solid barriers between animal 

enclosures to prevent direct contact – including splashed pool water and airborne disease 

transmission. 

• Ensure sufficient air turnover in indoor facilities to prevent transmission of disease. Air turnover 

should be enough to prevent build-up of heat or chemical fumes and provide a method of bringing 

fresh air into the facility. There should be sufficient venting or openings to allow movement of 

air throughout the facility. 

• Implement specific quarantine and sanitation procedures to prevent transmission of disease 

through fomites (personnel, clothing, equipment). 

• Thoroughly clean and disinfect buckets, hoses, scales, transport equipment, and cleaning 

equipment that is moved between animal areas to prevent transmission of pathogens via fomites. 

• Place open water pens so effluent is not near water intake. 

• Require evaluation and written veterinary approval before placing animals together after 

quarantine period has been met. 

RECOMMENDED 

• Provide separate air handling system in indoor facilities. 

• Clean and disinfect quarantine pools between uses. 

1.4.2 Prevention of Domestic Animal to Marine Mammal Transmission of 

Disease 

• Ensure appropriate fencing and placement of holding pens prevents direct contact between 

rehabilitating cetaceans and domestic animals. 

• Prohibit personal pets from entering the facility and facility grounds. Pets must stay outside the 

perimeter fence at all times. 

• Place foot baths at the entry and exit of animal areas. 

• Require quarantine and sanitation protocols are followed to prevent transmission of disease 

through fomites such as wet suits and equipment. 
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1.4.3 Prevention of Wild Animal to Marine Mammal Transmission of 

Disease 

• Ensure perimeter fencing will prevent wildlife from entering the rehabilitation premises. 

• Provide appropriate rodent and bird control on the premises. Ensure net pens and lagoon areas 

have sufficient secondary fencing to keep wildlife from coming in direct contact with the animals 

housed in the net pens. 

1.4.4 Prevention of Marine Mammal to Domestic Animal Transmission of 

Disease 

• Provide appropriate perimeter fencing. 

• Require animal personnel to change contaminated clothing and/or disinfect before leaving the 

rehabilitation premises. 

• Require that specific quarantine and sanitation procedures are taken to prevent transmission of 

disease through fomites such as clothing and equipment. 

1.4.5 Prevention of Stranded Marine Mammal to Captive Marine Mammal 

Transmission of Disease 

• Train volunteers and staff to follow appropriate quarantine protocols. 

• Establish quarantine protocols that take into consideration the changing status of the stranded 

animal. 

• Establish traffic flow so that volunteers or staff working with stranded animals do not 

inadvertently travel into a collection animal area. 

• Establish decontamination protocols before volunteers or staff members exposed to stranded 

animals may enter a collection animal area. 

• Establish separate restrooms, showers, changing rooms, food preparation areas, etc. for staff and 

volunteers working with rehabilitating vs. collection animals. Food for rehabilitating animals may 

be prepared in the collection animal kitchen and taken to the rehabilitation animal area, however 

any bucket, feed implement or other item must be thoroughly disinfected before it may return to 

the collection animal area. 
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1.4.6 Methods to Reduce Spread of Disease from Animals Housed in 

Open Sea/Bay Pen Systems 

• Consideration of substrate, water depth and public access when selecting a site for a sea or bay 

pen. 

• Placement of pens in a secluded area where wild animals and marine mammals are unlikely to 

come into direct contact with the animals housed in the sea/bay pens; nets should be sufficiently 

rigid to prevent entanglement by mammals or fish. 

• Placing a second set of perimeter nets 10 meters from the sea/bay pens to prevent direct contact 

with wild marine mammals. 

• Do not place sea/bay pens within 1000 meters of any major outflow of storm drains or sewage 

treatment plants and consider the flow direction or current from these major outflows. 

• Place the sea/bay pens over 500 meters and downstream from water intake pipes that bring water 

into facilities that house marine mammals. 

• Place pens in an area where there is ample flow-through of tides/currents. 

• Ensure the pens are of sufficient size to minimize biomatter build-up. Each cetacean should be 

housed in a pen that has a minimum depth of half of their body length, and a minimum horizontal 

dimension of 24 feet or two full body lengths, whichever is greater. 

• Avoid overcrowded pens. Animals may fight with each other when housed too closely together. 

Likewise they must be able to swim and dive normally to maintain optimal muscle condition. 

• Have equipment to pump or aerate the water in pens that do not have sufficient tidal action to 

ensure a minimum of two complete water changes per day. 

• Place pens in areas where there is sufficient depth to enhance water circulation and reduce 

pathogen build-up. Daily coliform testing will determine if pathogen build-up exists. 

• Place quarantine pens such that tidal action or underwater currents will not flow through sea pens 

housing healthy animals. 

1.4.7 Evaluation Requirements Before Placing Marine Mammals 

Together 

• Complete blood count (CBC)/Chemistries, appropriate cultures, physical examination before 

moving animals out of quarantine area. 

• Review current NMFS recommendations on diseases of concern (i.e. Morbillivirus) and 

reportable disease (i.e. Brucella and West Nile virus). 
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• Consider screening for morbillivirus, herpes virus, Brucella, Leptospira, and Toxoplasma 

utilizing the most current diagnostic tests available.

• If animals are part of a UME, then screening for diseases must be more thorough and in direct 

coordination with NMFS and through UME coordinators. 

• Have contingency plan for animals that are carriers of or actively infected with reportable disease 

such as brucellosis, herpes virus, leptospirosis, toxoplasmosis, and morbillivirus. 

1.4.8 Zoonotic Considerations 

• Restrict public access and direct contact with cetaceans due to zoonosis potential and public 

health hazard of non-trained individuals interacting with sick and injured marine mammals. 

• Train staff and personnel about how to prevent contracting zoonotic diseases (Occupational and 

Safety Information for Marine Mammal Workers http://www.vetmed.ucdavis.edu/whc/mmz/). 

• Train staff and personnel working directly with stranded cetaceans how to recognize symptoms of 

zoonotic disease. 

• Provide safety equipment such as protective clothing, eye protection and face masks. 

• Provide eye flushing stations as used with hazardous materials (HAZMAT) or normal saline 

bottles to irrigate the eyes. 

• Staff with open wounds shall not enter the pool of animals carrying potentially infectious 

diseases. 

• Persons with disabilities, respiratory conditions, infectious diseases or infectious skin conditions 

shall not enter pools with rehabilitating cetaceans. 

• Train staff the basics of sanitation and properly handling contaminated equipment. 

1.4.9 Pre-Release Guidelines 

• Pre-release health screens and serologic requirements are directed by the NMFS Regional 

Stranding Coordinator, in coordination with Marine Mammal Health and Stranding Response 

Program. 
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1.5 Sanitation 

MINIMUM STANDARD 

1.5.1 Primary Enclosure Sanitation 

• Remove animal and food waste in areas other than the rehabilitation pool from the rehabilitation 

enclosure at least daily, and more often when necessary to prevent contamination of the marine 

mammals contained therein and to minimize disease hazards. 

• Remove particulate animal and food waste from rehabilitation/exercise pools at least once daily, 

but as often as necessary to maintain water quality and to prevent increased health hazards to the 

marine mammals that use the pools. 

• Remove trash and debris from pools as soon as it is noticed, to preclude ingestion or other harm 

to the animals. 

• Clean the walls and bottom surfaces of the rehabilitation/exercise pools as often as necessary to 

maintain proper water quality. 

• Prevent animals from coming in direct contact with disinfectants or aerosolized disinfectants from 

spray or cleaning hoses. 

RECOMMENDED 

• Empty and allow pools to dry once each year but dry and hyperchlorine pool bottoms and walls 

after each use by sick cetaceans. 

1.5.2 Sanitation of Food Preparation Areas and Food Receptacles 

• Use separate food preparation areas and supplies for rehabilitation vs. collection animals. 

• Clean food containers such as buckets, tubs, and tanks, as well as utensils, such as knives and 

cutting boards, or any other equipment which has been used for holding, thawing or preparing 

food for marine mammals after each feeding with detergent and hot water and sanitize with an 

appropriate disinfectant approved for use in food areas at least once a day. 

• Clean kitchens and other food handling areas where animal food is prepared after every use, and 

sanitize at least once weekly using standard accepted sanitation practices. 

• Store substances such as cleaning and sanitizing agents, pesticides and other potentially toxic 

agents in properly labeled containers away from food preparation areas. 

• Post MSDS “right to know” documents for staff utilizing cleaning and animal treatment 

chemicals and drugs. 
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1.6 Food, Handling, and Preparation 

During rehabilitation food for marine mammals shall be wholesome, palatable, free from 

contamination, and of sufficient quantity and nutritive value to allow the recovery of the animals to a 

state of good health. Live fish may be fed during rehabilitation but preferences should be given to 

native prey species. Live fish may contain parasites which could infect compromised animals. 

Feeding regimens should simulate natural patterns in terms of frequency and quantity to the extent 

possible while following a prescribed course of medical treatment. Most cetaceans feed repeatedly 

during a given day. 

1.6.1 Diets and Food Preparation 

MINIMUM STANDARD 

• Prepare the diets with consideration for age, species, condition, and size of marine mammals 

being fed. 

• Feed cetaceans a minimum of three times a day, except as directed by a qualified veterinarian or 

when following professionally accepted practices. 

• Diets reviewed by a nutritionist, attending veterinarian, or the animal care supervisor. 

• Train staff to recognize good and bad fish quality. 

• Feeding live fish may be required for release determination. See NMFS /FWS Best Practices for 

Marine Mammal Stranding Response, Rehabilitation, and Release – Standards for Release for 

more information regarding feeding live fish. 

• Food receptacles should be cleaned and sanitized after each use. Food preparation and handling 

should be conducted so as to minimize bacterial or chemical contamination and to ensure the 

wholesomeness and nutritive value of the food. 

RECOMMENDED 

• Feeding patterns should simulate natural patterns in terms of frequency and quantity which may 

require food to be offered 5 – 10 times daily. 

1.6.2 Food Storage and Thawing 

MINIMUM STANDARD 

• Frozen fish or other frozen food shall be stored in freezers which are maintained at a maximum 

temperature of 0o F (-18oC). 
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• The length of time food is stored and the method of storage, as well as the thawing of frozen food 

should be conducted in a manner which will minimize contamination and which will assure that 

the food retains optimal nutritive value and wholesome quality until the time of feeding. 

• Freezers should only contain fish for animal consumption. Human food or specimens should not 

be placed in the fish freezer. 

• Experienced staff should inspect fish upon arrival to ensure there are no signs of previous 

thawing and re-freezing, and check temperature monitoring devices in the transport container. 

The fish shipment should be refused or the fish discarded if temperature fluctuations occurred 

during transport. 

• Freezers shall be of sufficient size to allow for proper stock rotation. 

• All foods shall be fed to the marine mammals within 24 hours following the removal of such 

foods from the freezers for thawing. 

• If the food has been thawed under refrigeration it must be fed to marine mammals within 12 

hours of complete thawing. 

• When fish is thawed in standing or running water, the coldest available running water must be 

used to prevent excess bacterial growth. 

• To ensure optimal quality of the fish, and to prevent bacterial overgrowth, do not allow fish to 

reach room temperature or sit in direct sunlight. 

• The thawed fish shall be kept iced or refrigerated until a reasonable time before feeding. This 

time will vary with ambient temperature. 

• Prepared formula should be fed immediately or refrigerated and fed to the marine mammals 

within 24 hours of preparation. Formula, once heated to an appropriate temperature for a feed, 

shall be discarded if it is not consumed within one hour. 

RECOMMENDED 

• Calculate kilocalories of each type of fish or food items fed to each animal daily. 

• Conduct food analysis for protein, fat and water content of each lot of fish used. 

• Culture the slime layer from the fish lot prior to thawing for Erysipelothrix. 

1.6.3 Supplements 

MINIMUM STANDARD 

• Each animal shall receive appropriate vitamin supplementation which is sufficient and approved 

in writing by the attending veterinarian. 
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1.6.4 Feeding 

MINIMUM STANDARD 

• Food, when given to each marine mammal individually or in groups, must be given by personnel 

who have the necessary training and knowledge to assure that each marine mammal receives and 

eats an adequate quantity of food to maximize its recovery or maintain good health. Such 

personnel is required to recognize deviations in each animal being rehabilitated such that intake 

can be adjusted and/or supplemented accordingly. 

1.6.5 Public Feeding 

MINIMUM STANDARD 

• Public feeding of animals that are being rehabilitated is strictly prohibited. 

• Feeding must be conducted only by qualified, trained personnel. 

1.6.6 Feed Records 

MINIMUM STANDARD 

• Maintain feed records on each individual animal noting the actual (not an estimate) individual 

daily consumption for each animal by specific food type. 

• If non-critical animals are housed in groups and are broadcast-fed, then daily individual food 

consumption estimates are acceptable 

• Weigh food before and after each feeding and the record the amount consumed. 

• Obtain body weight or girth measurements at least weekly from debilitated easily-handled 

animals. Girth measurements are taken at the level of the axilla and the anterior insertion of the 

dorsal fin. Girth measurements are generally less stressful to obtain than weighing the animal. 

• Girth measurements or body weight should be obtained as often as practical in the later stages of 

rehabilitation without causing undue stress to the animal. 

1.7 Veterinary Medical Care 

All rehabilitation facilities shall have an attending veterinarian. The attending veterinarian is 

critically involved in making decisions regarding medical care as well as housing and husbandry of 

resident and newly admitted patients. 
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1.7.1 Veterinary Experience 

MINIMUM STANDARD 

The attending veterinarian shall: 

• Assume responsibility for diagnosis, treatment, and medical clearance for release or transport of 

marine mammals in rehabilitation (50 CFR 216.27). 

• Ability to provide a schedule of veterinary care that includes a review of husbandry records, 

visual and physical examinations of all the marine mammals in rehabilitation, and a periodic 

visual inspection of the facilities and records. 

• Be available to examine animals on a regular schedule and emergency basis; daily if necessary. 

• Be available to answer veterinary questions on a 24 hour basis. 

• Have marine mammal experience or be in regular consultation with a veterinarian who has 

marine mammal experience and have access to a list of expert veterinarians to contact for 

assistance. 

• Have an active veterinary license in the United States (means a person who has graduated from a 

veterinary school accredited by the American Veterinary Medical Association Council on 

Education, or has a certificate issued by the American Veterinary Graduates Association's 

Education Commission for Foreign Veterinary Graduates), or has received equivalent formal 

education as determined by NMFS Administrator (adapted from the Animal Welfare Act 

Regulations 9 CFR Ch. 1). 

• Have the skills to be able to draw blood from, and give injections to the species most commonly 

encountered at the rehabilitation center. 

• Be available to examine animals immediately upon admittance to a facility. 

• Be available to assess animals during a mass stranding directly or indirectly through trained and 

qualified primary responders. 

• Have contingency plan for veterinary backup. 

• Have the appropriate registrations and licenses (e.g., registered with the Drug Enforcement 

Administration for handling controlled substances) to obtain the necessary medications for the 

animals housed at that rehabilitation facility. 

• Be able to conduct a full post-mortem examination on all species of cetaceans treated at the 

facility. 

• Be knowledgeable and able to perform cetacean euthanasia. 

• Be knowledgeable about species-specific pharmacology. 
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• Must certify in writing that animals are fit for transport. 

• Ability to write and submit timely disposition recommendations for marine mammals in 

rehabilitation. 

• Be knowledgeable of marine mammal zoonotic diseases. 

RECOMMENDED 

All of the above plus: 

• Membership in the International Association for Aquatic Animal Medicine. 

• Have access to a current version of the CRC “Handbook of Marine Mammal Medicine” 

• Complete a course that offers basic medical training with marine mammals such as Seavet, 

Aquavet, or MARVET. 

• Have a minimum of one year of clinical veterinary experience post graduation. 

• Have at least one year clinical experience working with the marine mammal type(s) most 

frequently admitted to the rehabilitation facility 

• Be full time employees or contracted veterinarian experienced in cetacean medicine at facilities 

managing an average of 5 live cetacean cases per year. 

1.7.2 Veterinary Program 

MINIMUM STANDARD 

• Veterinary care for the animals must conform with any State Veterinary Practice Act or other 

laws governing veterinary medicine which applies to the state in which the facility is located. 

• Standard operating procedures should be reviewed and initialed by the attending veterinarian or 

the animal care supervisor annually and/or whenever the document is changed or updated. This 

document may be reviewed by NMFS as part of the NMFS Stranding Agreement or as part of 

inspections. 

• Staff caring for animals should be sufficiently trained to assist with veterinary procedures under 

the direction of the veterinarian and the rehabilitation facility should maintain at least one Animal 

Care Supervisor who is responsible for overseeing prescribed treatments, maintaining hospital 

equipment, and controlling drug supplies. The person should be adequately trained to deal with 

emergencies until the veterinarian arrives, be able to direct the restraint of the animals, be 

responsible for administration of post-surgical care, and be skilled in maintaining appropriate 

medical records. It is important that the animal care supervisor should communicate frequently 
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and directly with the attending veterinarian to ensure that there is a timely transfer of accurate 

information about medical issues. 

• Veterinary decisions shall be based on “best practices” (i.e., based on informed opinions and 

expertise of veterinarians practicing marine mammal medicine). 

• A schedule of veterinary care which includes a review of husbandry records, visual and physical 

examinations of the animals, and a visual inspection of the facilities should be implemented. 

• A health and safety plan for the staff shall be written and accessible at all times. It shall be 

reviewed by the attending veterinarian or the animal care supervisor annually or as prescribed by 

the NMFS Stranding Agreement. Also, it may be beneficial to consult with an occupational health 

medical professional when developing these plans. All animal care staff will be familiar with the 

plan. The plan shall include protocols for managing bite wounds. 

The following reports may be requested annually by NMFS as required under the NMFS Stranding 

Agreement or as a part of inspections: 

• Standard Operating Procedure (SOP) reviews 

• Health and Safety Plan reviews 

• Animal acquisitions and dispositions 

• National Oceanic and Atmospheric Administration (NOAA) Form 89864, Office of Management 

and Budget (OMB) #0648-0178 (Level A data) 

• NOAA Form 89878, OMB#0648-0178 (Marine Mammal Rehabilitation Disposition Report) 

• Case summaries for any rehabilitation performed at a facility, including narrative descriptions of 

the cases as well as spreadsheets of treatments, blood values, etc. 

1.8 Laboratory Tests and Frequency of Testing 

Specific requirements for tests will be issued by the NMFS stranding coordinator (or UME Onsite 

Coordinator) in each region as outlined in the Marine Mammal Health and Stranding Response 

Program for release determinations, surveillance programs and UME investigations. Routine 

diagnostic sampling and testing protocols will be determined by the attending veterinarian. NMFS 

must be provided adequate time and information including a veterinary certificate of health before an 

animal is released as directed in 50 CFR 216.27 (see NMFS/FWS Best Practices for Marine Mammal 

Stranding Response, Rehabilitation, and Release – Standards for Release ). 
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1.8.1 Laboratory Testing 

MINIMUM STANDARD 

• CBC/Serum Chemistry- For most cases, all animals shall have a minimum of two blood samples 

drawn for CBC with differential and serum chemistry; upon admission and prior to release (see 

NMFS/FWS Best Practices for Marine Mammal Stranding Response, Rehabilitation, and Release 

– Standards for Release ). If duration of rehabilitation is shorter than a week, one blood workup 

may suffice and is at the attending veterinarian’s discretion. 

• Fecal analysis for parasites - Fecal tests for parasites shall be run upon admission of each animal 

at the discretion of the attending veterinarian. 

• Serology as necessary for release determination based on direction of the NMFS stranding 

coordinator and the Marine Mammal Health and Stranding Program and for additional clinical 

diagnosis as deemed appropriate by the attending veterinarian. 

• The administration of drugs with potential adverse side-effects may require additional testing. 

For example, the use of ototoxic antibiotics may require subsequent testing of hearing abilities of 

the animal prior to consideration for release. 

• The attending veterinarian or a trained staff member shall perform a necropsy on every animal 

that dies within 24 hours of death if feasible. If necropsy is to be performed at a later date 

(ideally no longer than 72 hours postmortem), the carcass should be stored appropriately to delay 

tissue decomposition. 

• Carcass disposal shall be handled in a manner consistent with local and state regulations. 

• Perform histopathology on select tissues from each animal that dies at the discretion of the 

attending veterinarian. A complete set of all major tissues should be evaluated if the animal dies 

of an apparent infectious disease process. 

• Culture and other diagnostic sampling shall be conducted as directed by the attending veterinarian 

to determine the cause of stranding or death. 

• Contact NMFS for additional laboratory test requirements in all cases of unusual mortality 

outbreaks or disease outbreaks. More complete testing may be required for diseases of concern. 

• For cases involving release decisions, unusual mortality investigations, or surveillance programs, 

serologic assays may only go to labs that have validated tests approved by NMFS, especially for 

release decisions or determinations. Guidance will be provided by the NMFS Stranding 

Coordinators or UME Onsite Coordinator. 
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• Notify the NMFS Stranding Coordinator of learning of any diseases of concern (e.g., emerging, 

reportable, and/or zoonotic diseases) that are detected and/or confirmed that could be a potential 

hazard for public health or animal health (NMFS will provide guidance on reportable diseases as 

it becomes available). 

• NMFS must be provided adequate time and information (including veterinary certificate of 

health) before the animal is released in all cases as directed in 50 CFR 216.27 (see NMFS 

Standards for Release). This information is required under 50 CFR 216.27(a) and must be 

submitted 15 days prior to release unless advanced notice is waived by the NMFS Regional 

Administrator. Guidance on the waivers is provided in the NMFS/FWS Best Practices for Marine 

Mammal Stranding Response, Rehabilitation, and Release – Standards for Release.

RECOMMENDED 

• Complete necropsy performed by the attending veterinarian or a pathologist within 24 hours of 

death. 

• Full histopathology done on tissues from each animal that dies of apparent infectious disease. 

• Bank 1cc of serum per blood draw in –80o F freezer. 

• Bank heparinized plasma (green top) tube in –80 o F one per animal. 

• Reproductive status shall be evaluated upon admission and prior to release through analysis of 

serum progesterone and estrogen levels in females, and testosterone in males. Elevated hormone 

values in females upon admission will require re-sampling within the first two weeks to assess 

pregnancy. Monitoring by means of monthly blood sample collection and analysis through the 

course of rehabilitation is strongly advised. If possible, sampling will be done in conjunction 

with ultrasonic examination of reproductive tracts. 

1.9 Record Keeping and Data Collection 

Record keeping is an essential part of the rehabilitation process. Not only do accurate and complete 

medical records for each stranded cetacean allow the staff to provide consistent and optimal care for 

each animal, but retrospective records help scientists and veterinarians to make better evaluations on 

how to treat individuals. 

1.9.1 Record Keeping 

MINIMUM STANDARD 

• Record and report the “Marine Mammal Stranding Report - Level “A”. 
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• Complete the require NMFS Marine Mammal Rehabilitation Disposition Report NOAA 89-878, 

OMB #0648-0178.as in accordance with the NMFS Stranding Agreement 

• Maintain and update individual medical records daily on each animal at the rehabilitation center. 

• Individually identify each animal with unique field number. 

• Keep an accurate description of the animal, including identification/tag number, date and location 

of stranding, sex, weight, and length at stranding. 

• Subjective, objective, assessment and plan (SOAP) based records are preferred. 

• Include food intake and medication administered to each animal in the daily records. 

• Weight 

a. Recorded weekly for underweight cetacean calves or as authorized in writing by the attending 

veterinarian. 

b. Taken as often as possible for underweight animals without causing undue stress to the 

animal. 

c. Recorded on admission and prior to release for larger cetaceans. 

• Measure body weight, girths (axilla and anterior insertion of the dorsal fin) and standard straightline and length upon admission, and within one week of release/placement. 

• Measure blubber thickness (ultrasonically) at standard sites upon admission, and monitor monthly 

throughout the course of rehabilitation, with a goal of matching blubber to seasonal water 

temperatures. 

• Weigh the animal as practical, keeping in mind that obtaining the weight of the animal may be 

stressful. 

• Record all treatments, blood work, test and results and daily observations in the medical records. 

• Maintain individual medical records for each animal. Medical records remain on site where the 

animal is housed and are available for NMFS on site review upon request as stated in the NMFS 

Stranding Agreement. 

• Maintain medical records in an accessible format on site for a minimum of 15 years. 

• Maintain up to date water quality records for a minimum of two years. 

• Maintain life support system maintenance records. 

• Maintain records of water quality additives. 

RECOMMENDED 

• Full set of standard morphometrics prior to release. 

• Photographic documentation, identifying marks, lesions. 
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• Caloric value of daily food intake calculated and recorded for each animal each day 

• Daily weight of calves or emaciated animals at the discretion of the attending veterinarian. 

• Maintain food acquisition and analysis records. 

• Maintain “paper copy” archive of required NMFS records. 

1.9.2 Data Collection 

MINIMUM STANDARD 

• Written documentation of the medical history, food and observation records must be kept. 

• NMFS Required Forms to be completed in writing or submitted electronically in the NMFS 

National Marine Mammal Stranding Database as prescribed in the NMFS Stranding Agreement: 

a. Marine Mammal Stranding Report – Level A (NOAA 89-864, OMB #0648-0178) 

b. Marine Mammal Rehabilitation Disposition Report (NOAA 89-878, OMB #0648-0178) 

RECOMMENDED 

• Computerized documentation with hard copies. 

• Ability to network with other institutions. 

• Maintain real-time accessible compiled comparative data. 

1.10 Euthanasia Protocols 

MINIMUM STANDARD 

• Each institution must have a written euthanasia protocol signed by the attending veterinarian. 

• Persons administering the euthanasia must be knowledgeable and trained to perform the 

procedure. 

• Maintain a list of individuals authorized to perform euthanasia signed by the veterinarian. 

• Euthanasia shall be performed in a way to minimize distress in the animal. 

• Refer to resources such as the American Veterinary Medical Association Panel Report on 

Euthanasia, the CRC Press Handbook of Marine Mammal Medicine and American Association 

for Zoo Veterinarians Guidelines for Euthanasia of Nondomestic Animals. 

• Appropriate drugs for euthanasia in appropriate amounts for the largest species admitted to the 

facility shall be maintained in stock on site in an appropriate lockbox or under the control of a 

licensed veterinarian with a current Drug Enforcement Administration (DEA) license. 

• Drugs for euthanasia shall be kept with an accurate inventory system in place. 
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• DEA laws and regulations and any applicable State Veterinary Practice Acts must be followed 

when using controlled drugs. 

• NMFS may request this information (protocols and DEA number) as part of the NMFS Stranding 

Agreement. 

1.11 Health and Safety Plans for Personnel 

There shall be a health and safety plan on site at each rehabilitation facility that identifies all health 

and safety issues that may be factors when working closely with wild marine mammals. The plan 

should identify all potential zoonotic diseases as well as including safety plans for the direct handling 

of all species and sizes of cetaceans seen at that facility. Rehabilitation facilities are encouraged to 

comply with Occupational Safety and Health Administration regulations. 

MINIMUM STANDARD 

• Identify all potential zoonotic diseases in a written document available to all personnel. 

• Include safety plans for the direct handling of all species and sizes of cetaceans seen at that 

facility. 

• Include safety plan for dealing with handling any untreated discharge water. 

1.12 Contingency Plans 

Contingency plans shall be in place at each facility and may be required by NMFS as part of the 

NMFS Stranding Agreement. NMFS may require approved variances or waivers prior to planned 

projects such as construction, and NMFS may not allow rehabilitation efforts to occur under some 

circumstances. These plans should addresses in detail the operation of the facility and care of the 

animals under the following conditions: 

• Inclement weather plan, including a hurricane/big storm plans where appropriate. 

• Construction in the vicinity of the animal rehabilitation pools recognizing the potential and 

documented adverse impacts of construction on cetaceans, and including specific reference to 

how noise, dust, debris, and construction worker access will be controlled, how and how 

frequently animal health will be monitored, and specific criteria for when construction shall be 

halted or the animals will be moved to another site out of the construction area if the animals 

appear to be adversely impacted. 

• Power outages, including plans of how to maintain frozen fish stores and life support systems. 
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• Water shortages. 

• “Acts of God” plan which may include floods, earthquakes, hurricanes or other unpredictable 

problems known to occur on occasion in the region where the facility is located. 

1.13 Viewing 

 NMFS Regulation, U.S.C. 50 CFR 216.2(c)(5) states that marine mammals undergoing rehabilitation 

shall not be subject to public display. The definition of public display under U.S.C. 50 CFR is “an 

activity that provides opportunity for the public to view living marine mammals at a facility holding 

marine mammals captive”. Only remote public viewing or distance viewing should be allowed and 

only when there is no possible impact of the public viewing on the animals being rehabilitated. 

There is a regulatory requirement for a variance or waiver by NMFS for facilities planning to offer 

public viewing of any marine mammal undergoing rehabilitation.

1.14 Training and Deconditioning Behaviors 

Basic behavioral conditioning of wild cetaceans for husbandry and medical procedure may be 

warranted during rehabilitation as long as every effort is made to limit reinforced contact with 

humans. Such conditioning may reduce stress for the animal during exams and acquisition of 

biological samples. Conditioning may assist with appetite assessment and ensuring that each animal 

in a group receives the appropriate amount and type of diet and medications. 

In some cases, extensive contact with humans, including training, may benefit resolution of the 

medical case by providing mental stimulation and behavioral enrichment, and may facilitate medical 

procedures. The relative costs and benefits of training should be evaluated by the attending 

veterinarian and animal care supervisor and the likelihood of contact with humans following release 

should be considered. Seeking advice from a qualified cetacean behaviorist (with at least 3 years of 

experience) may be beneficial. 

Behavioral conditioning of cetaceans must be done for the shortest time necessary to achieve 

rehabilitation goals and is to be eliminated prior to release such that association of food rewards with 

humans is diminished. If an animal has become accustomed to hand-feeding or boat-following, the 

animal may approach humans after release. Therefore, these behaviors should be deconditioned or 

counter-conditioned before the animals can be considered for release. Most behaviors will extinguish 

through lack of reinforcement, but some may require more concentrated efforts. 
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Training for research that is above and beyond the scope of normal rehabilitation practices can be 

approved on a case-by case basis under a NMFS scientific research permit. An exception can be 

made if the attending veterinarian, facility, and NMFS officials all agree that the research will not be 

detrimental to the animals' health and welfare and will not impede their ability to be successfully 

released back to the wild. 
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2. Standards for Pinniped Rehabilitation Facilities 

2.1 Facilities, Housing, and Space 

Pools for stranded pinnipeds must be appropriate for the basic needs of the animal including 

buoyancy and thermoregulation. Debilitated pinnipeds often cannot swim and will avoid water if 

offered, preferring a haul-out space to a pool. Pinnipeds arriving in a debilitated condition have 

different needs and may not require pools initially. If no pool is provided to the animal, means of 

keeping it wet and protected from direct sunlight is essential. The upper critical temperature of 

California sea lions is lower than most land-dwelling mammals at 24°C (75°F) and with limited 

thermoregulatory ability, they have special habitat needs in captivity. While dry sea lion coats absorb 

about 74% and wet California sea lion coats absorb almost 92% of all types of shortwave radiation 

respectively, a California sea lion with a wet coat exposed to direct sunlight could easily overheat on 

a hot day if there were no other method to cool the animal. (Langman et al., 1996). 

Social compatibility should be considered as a part of appropriate housing. Pinnipeds known to be 

social should be housed with compatible species whenever possible. Placing larger, more robust 

animals in separate pens, away from the smaller, weaker, or less dominant animals may enhance the 

success of the rehabilitation efforts for the weaker animals. 

It is up to the attending veterinarian and experienced rehabilitation staff, to decide how to house the 

animal most appropriately based on their experience, observations, and physical examination. 

Each animal admitted to a rehabilitation center should be placed in a quarantine holding area and 

have a full health evaluation performed by the attending veterinarian, Sufficient quarantine time 

should be allowed for results from tests and cultures to be evaluated before the animal is placed with 

animals that are apparently disease free. Pinnipeds with evidence of infectious disease must be held 

in separate areas from other rehabilitating animals to prevent transmission of disease. There should be 

sufficient isolation areas to accommodate incoming animals with evidence of disease utilizing 

methods to control aerosol and water-borne exposure to other on-site animals. (See Section 2.4 

Quarantine).

During multiple or unusual stranding situations such as hazardous waste spills, catastrophic weather 

events, toxic algal blooms, or other events leading to unusually high morbidity or mortality, 

rehabilitation centers may need to adjust the number of animals that would be normally housed in 

each pen, pool, or bay or ocean pen. The attending veterinarian will be responsible for assuring that 
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numbers of animals housed in one pool or pen will be appropriate based on the situation. The number 

of qualified animal care personnel available to care for the animals could be a limiting factor on how 

many animals may be housed at each facility. 

Care should be taken when hand rearing neonatal otariids, as some species frequently imprint on their 

caregivers rendering them unsuitable for release. A plan for placing animals in a permanent captive 

environment should be in place in advance for pinniped pups that are ultimately deemed unreleasable. 

NMFS Regulation, U.S.C. 50 CFR 216.2(c)(5) states that marine mammals undergoing rehabilitation 

shall not be subject to public display. The definition of public display under U.S.C. 50 CFR is “an 

activity that provides opportunity for the public to view living marine mammals at a facility holding 

marine mammals captive” (See Section 2.13 Viewing). 

2.1.1 Pool Requirements 

MINIMUM STANDARD 

• Pools shall be available for all pinnipeds under rehabilitation. Critical care animals may be 

temporarily held without water access at the discretion of the attending veterinarian. 

• Critically ill animals or young pups are to be housed appropriately, with the pool size and depth 

as well as the dry resting area determined by the discretion of the attending veterinarian. 

• Pools shall be deep enough for each animal to completely submerge, and shall be at least 0.76 

meters or 2.5 feet deep. An exception to this would be temporary pools for young pups or 

debilitated animals. 

• Pools shall be large enough in diameter to allow each animal housed therein to swim. 

RECOMMENDED 

• Pools shall have a MHD of 1 meter or 1.5 x the length of the largest animal utilizing the pool, 

whichever is larger. 

• The minimum surface area of the pool for non-critical animals shall be at least equal to the dry 

resting area required by USDA, APHIS AWA standards, but using the actual length of the largest 

animal in the enclosure instead of the average adult length. 

• The pool shall be at least 0.91 meters deep or one-half the actual length of the longest species 

contained therein, whichever is greater. 
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• If adult pinnipeds are commonly rehabilitated, facilities should be designed to accommodate the 

average number of adult-sized animals that strand each year, and have at least one pool and haulout area that meet USDA APHIS AWA standards. 

2.1.2 Dry Resting Area

MINIMUM STANDARD 

• One non-critical animal; area of dry resting area = 1.2 x (length of the animal)2

. 

• Two non-critical animals; area of dry resting area = 1.5 x (length of the longest animal) 2. 

• Three or more animals in the same enclosure require the minimum space for two animals and, in 

addition, enough space for the animals to lay separately with at least one body length from one 

another, to turn around completely, and to move at least two body lengths in one direction. 

• The facility must have a plan to manage adult males. 

• Animals may be temporarily housed in smaller areas at the discretion of the veterinarian. The 

attending veterinarian should determine the minimum space which will be most appropriate for 

the age or medical condition of the animal. 

• Critical care animals and young pups may be temporarily supplied smaller pools and less dry 

resting area. 

RECOMMENDED 

• One to two animals: 2 x (length of longest animal)2

• Three or more animals in the same enclosure: (length of each animal)2 x number of animals in 

enclosure = number of square feet of required dry resting area (DRA). 

2.1.3 Pool or Pen Design 

New rehabilitation pools should be designed and constructed to minimize introduction of 

anthropogenic noise from life-support equipment or other sources. This can be accomplished through 

sloping of walls, insulation with soil or other materials around the sides of the pool and/or through 

isolation of noise-generating equipment. A special exception may be granted by NMFS if existing 

pools do not meet these specifications and a retrofit is not feasible as long as animal welfare is 

maintained. 

MINIMUM STANDARD 

• Pools or pens shall be designed for ease of cleaning and handling the animals. 
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• Open water pens shall optimally be constructed of plastic or other rigid netting.

• If cotton or nylon netting material is used it must be small enough gage to prevent entanglement. 

RECOMMENDED 

• Pools designed to promote good water circulation and to minimize anthropogenic noise. 

• Ability to drop a pool in less than 2 hours and refill it to a “swimming level” in less than 30 

minutes or a false bottom or other method utilized for ease of capturing and treating pinnipeds. 

2.1.4 Length of Stay and How it Affects Space 

Facilities which handle adult animals that are kept for periods longer than six months but less than 

one year should meet USDA APHIS AWA standards. However the actual length of each animal may 

be used for each DRA calculation rather than the adult length. After one year, holding space must 

meet APHIS standards. 

2.1.5 Shelter, Shading, and Lighting 

Animals housed at rehabilitation facilities must be provided with shelter to provide refuge from 

extreme heat or cold. Pinnipeds held in rehabilitation facilities may not have normal activity levels 

and thin animals may be unable to thermoregulate properly. These animals may require shade 

structures to protect them from direct sunlight and extreme heat, or shelter to protect them from cold 

temperatures or inclement weather. Animals held in indoor facilities should be provided with 

appropriate light and dark photoperiods which mimic actual seasonal conditions. At the discretion of 

the attending veterinarian an exception to refuge from extreme cold during the pre-release 

conditioning phase may be made. Pinnipeds should be protected at all times from extreme heat. 

MINIMUM STANDARD 

• Provide shade structures or shelters to animals to aid thermoregulation when local climatic 

conditions could compromise the health of the animal. 

• Provide shade and/or water spray to all pinnipeds that cannot swim and are housed in areas where 

ambient air temperatures reach > 80° F (26.6° C). 

• Lighting in indoor facilities shall be appropriate for the species and shall clearly illuminate the 

DRA and pool during daylight hours. 
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RECOMMENDED 

• All of the above and a source of natural or full spectrum light for animals housed indoors. 

• Removable or adjustable shade structures that may be sanitized regularly in pens to provide more 

natural sunlight to animals that are swimming and diving normally. 

2.1.6 Air Temperature 

MINIMUM STANDARD 

• Attention to ambient air temperature and humidity should be considered to facilitate recovery, 

protect rehabilitating animals from extremes of heat or cold, and to prevent discomfort. 

• Method to raise or lower air temperature, as appropriate to maintain proper body temperature 

should be available. Access to full shade, constant water sprays and fans may be used for animals 

that have no access to pools during times when the ambient temperature exceeds 85°F (29.4°C). 

Likewise radiant heating devices or waterproof heating pads may be utilized when ambient 

temperatures fall below the comfort level of the animal, which will be determined by the species, 

age, medical condition, and body condition of the animal. 

• Animals should be able to move away from point source heaters. If animals are too debilitated to 

move, temperature of heaters can not exceed the safe range of 60-80o

F at skin surface or animals 

must be monitored every 2 hours. 

• Large fans or “swamp coolers” available to move air across animals with no access to pools when 

ambient temperatures reach over 85°F (29.4°C). 

RECOMMENDED 

• Provide temperature-controlled shelter or holding space for critical care animals or pups. 

• Monitor temperature of additional heaters such as heating pads infrared heaters and heat lamps. 

2.1.7 HOUSING FOR CRITICAL CARE ANIMALS 

Debilitated and ill pinnipeds are often sedentary and haul out or float at the surface of a pool for long 

periods of time. Young pups may be weak and require assistance moving in and out of pools. A 

shallow area that allows the animal to rest on the bottom with gradually sloping sides or a ramp 

equipped with a gripping surface to allow ease in entering and exiting the pool are considered 

optimal. 
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MINIMUM STANDARD 

• Individual dry haul out space or individual enclosures shall be large enough to accommodate the 

most common species of pinnipeds rehabilitated routinely at the facility. 

• Housing for critically ill animals that will provide shelter from the extremes of heat or cold, and 

will provide heat as appropriate for animals held in cold climates. 

• Access to shallow water and/or water spray for all pinnipeds as advised by the attending 

veterinarian. 

• Barriers sufficient to isolate incoming animals until the attending veterinarian determines them to 

be free from contagious disease (See Section 2.4 Quarantine). 

RECOMMENDED 

All of the above minimum standards, plus: 

• Individual enclosures for each critical care animal where the dry resting area = (length of the 

animal)2. 

• Housing which provides optimal temperature control for critically ill animals (heating and/or air 

conditioning). 

2.1.7 Housing of Pups 

Pups of all species have special housing and management needs and require careful monitoring when 

introducing them to pools. Premature pups may require more time than full-term pups before 

introducing them to water. 

MINIMUM STANDARD 

Phocids less than 1 week old: 

• Individual housing with fully supervised access to shallow water (< 0.5 meters deep) pools. Full 

supervision may stop when animals demonstrate ability to swim and haul out. 

Otariids less than 3 weeks old: 

• Individual housing or housing with similarly sized pups with fully supervised access to shallow 

water pools (<0.5 meters deep) Full supervision may stop when animals demonstrate ability to 

swim and haul out. 
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• Access to raised platforms in dry resting areas for pups of all ages at the discretion of the 

veterinarian. Critical or debilitated pups should not be required to lay on concrete or other 

hard/cold surfaces. Platforms must be low enough for easy access yet high enough to allow the 

floor to dry under platform. Platforms should be made of material with a sealed cleanable surface 

and designed to allow for waste to pass through.

RECOMMENDED 

• All of the above and with pools designed with a gently sloping side/beach area with “gripping 

surface” to allow pups to easily haul out without assistance. 

2.1.8 Housing of Older Pups 

Full term phocids greater than 1 week old and otariids greater than three weeks old 

MINIMUM STANDARD 

• House pups with similar conspecific age group. 

• House pups as individuals or groups with frequent or constant access to deeper water (> 0.5 

meters deep). 

• Provide a platform or shallow shelf in each pool that allows pups to easily haul out on their own. 

• Provide platforms in dry resting areas allowing critical or debilitated pups an alternative to laying 

on concrete or other hard/cold surfaces (as above). 

RECOMMENDED 

• Provide a pool designed with a gently sloping side leading to a level beach area that allows pups 

to easily haul out. 

2.1.9 Number of Animals Housed in Each Pen/Pool 

During UME strandings, the number of pinnipeds received by the facility is limited not only by the 

number and size of the holding pools or pens, but the number of qualified trained rehabilitation staff 

members available to care for the animals. The maximum number of animals maintained in each pool 

and onsite at the facility shall be determined by the attending veterinarian and dictated by the number 

of qualified staff available to care for the animals. 
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MINIMUM STANDARD 

• Provide a minimum of three qualified trained rehabilitation staff members on site for the first 25 

pinnipeds housed at the facility, and two more trained rehabilitation staff members for every 

additional 25 pinnipeds. More staff will be required when animals are housed simultaneously in 

quarantine holding and recovering animal holding areas. Dependant pups are more labor 

intensive and require more staffing. Staff must be available on a 24-hour basis for critical animal 

care. 

2.1.10 Housekeeping 

MINIMUM STANDARD 

• Keep support buildings and grounds as well as areas surrounding rehabilitation pools clean and in 

good repair. 

• Maintain perimeter fences in good repair, and ensure they are an adequate height and construction 

to keep people and animals and pests out. 

• Ensure primary enclosures housing marine mammals do not have any loose objects, sharp 

projections, and/or edges which may cause injury or trauma to the marine mammals contained 

therein. 

• No holes or gaps larger than 1⁄2 the size of the head diameter of the pup of the smallest species to 

be housed. 

• All drains and overflows must have screened covers. 

• Objects introduced as environmental enrichment must be too large to swallow and made of non 

porous cleanable material. 

RECOMMENDED 

• Coat all pool and haul-out surfaces with a non-porous, non-toxic, non-degradable cleanable 

material that is able to be disinfected. 

2.1.11 Pest Control 

MINIMUM STANDARD 

• Establish and maintain a safe and effective program for the control of insects, avian and 

mammalian pests. This should include physical barriers to help to prevent feral and/or wild 

animals from contact with the rehabilitating animals. 
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• Insecticides or other such chemical agents shall not be applied in a primary enclosure housing 

marine mammals or a food preparation area except as authorized in writing by the attending 

veterinarian. 

• If applied, all appropriate measures must be taken to prevent direct contact with the 

insecticide/pesticide, whether airborne or waterborne, by the animal. 

2.1.12 Security for Facility 

Stranded marine mammals often attract public attention and must be protected from excessive 

commotion and public contact. Ensuring a quiet stress-free environment for rehabilitating animals 

may improve their chance to recover and survive. Public viewing of marine mammals is discussed in 

Section 2.13 of this document. 

MINIMUM STANDARD

• Locate rehabilitation facilities at sites that are able to be secured from the public. 

• Prevent direct public contact with the rehabilitating animals by utilizing appropriate fencing, staff 

and security personnel. 

RECOMMENDED 

• Maintain 24- hour monitoring when animals are present or maintain a secure perimeter fence with 

the ability to lock the area off to the public when staff is not present. 

2.2 Water Quality 

There are four basic types of water systems: 

• Pools with filtration systems (closed systems) 

• Pools without filtration systems (dump and fill systems) 

• Pools with periodic influx of natural seawater (semi-open systems) 

• Open water systems (Bay or sea pens). 

There are a number of variables which will affect water quality. The number and size of pinnipeds 

utilizing each pool will vary throughout the year at most rehabilitation institutions. During the busy 

season or during unusual stranding events, the number of pinnipeds utilizing one pool may increase 

dramatically creating a heavier load of waste which must be handled by the filtration system in closed 

systems and by the amount of water flow-through in semi-open and open systems. A life support 
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system is used as one tool in a program of water quality maintenance to provide safe and clean water 

to the animals. 

Filtration or life support systems are essential to maintaining clean water for animals held in closed or 

semi-closed systems. Life support systems have three basic parts; mechanical filters that remove 

solids, biological filters or baffles to remove or detoxify chemicals in the water, and disinfecting 

methods to control or remove pathogens. In addition to maintaining clean water in the animal pools, 

these systems may be needed to treat waste water, depending on waste water disposal requirements. 

If a temporary increase in waste production overwhelms part or all of the life support system, a good 

water quality control program will require alternative options. 

Water used in closed systems generally is fresh water obtained from municipal sources, whereas 

water in open and semi-open systems comes from a bay or sea source. Water in closed systems must 

be regularly filtered through sand and gravel filters to remove particulate matter, and disinfectants 

such as chlorine or bromine may be added to eliminate pathogens. More elaborate systems utilize 

ozone to oxidize pathogens in the water. The source should be independent of other rehabilitation 

and captive animal areas. 

 Factors that affect water quality are: 

• Size of pool or pen 

• Efficiency of filtration system or water flow-through rate (tides) 

• Water turnover rate 

• Number, size and species of animals housed in pool or pen 

• Type and amount of food consumed by animals in pool or pen 

• Nature of bottom substrate 

• Frequency of cleaning the pool 

• Types, amounts, method and the frequency with which chemicals are added to the system 

• Temperature of the water 

• Pathogens in the water 

• Biotoxins in open water pens or in pools where the source water comes from the ocean or bay 

• Contaminants (oil, pesticides, etc.) in open water pens 

• Hazardous waste spills 

• Inclement weather 

• Sunlight contributing to algae production on pool surfaces, which in turn can support bacteria. 
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2.2.1 Water Source and Disposal 

The water source for pinnipeds housed in closed or semi-closed systems may be municipal water, 

well water, or water brought into the facility from an adjacent body of water or estuary. The source 

should be independent of other rehabilitation and captive animal areas. 

MINIMUM STANDARD 

• Fresh or salt water must be readily available to fill pools, and fresh water to clean and wash down 

holding pens daily. 

• Drain water as often as necessary to keep the pool water quality within acceptable limits. 

• Discharge waste water in accordance with state or local regulations. Facility managers must seek 

appropriate authorization to dispose of waste water. Documents of authorization or necessary 

permits must be kept on site as part of the administrative record and may be requested by NMFS 

as part of the NMFS Stranding Agreement. 

• Chemicals, when necessary, shall be added in appropriate amounts to disinfect the water or adjust 

the pH, but not added in a manner that could cause harm or discomfort to the animals. 

• Have contingency protocols describing how water quality will be maintained during periods of 

peak animal use. 

• Water will be clear enough to see animals and bottom of pool and free from obvious solid waste 

and noxious odors. 

RECOMMENDED 

• Fresh or ideally salt water must be available to fill pools within two hours of draining. 

• Maintain a filtration system designed to optimize water quality in each holding pool and decrease 

water waste. 

• Ability to dechlorinate fresh water for species which require this (i.e., fur seals). 

• Protocols in place for maintenance of water quality throughout the year. 

• Testing of source and discharge water. 

2.3 Water Quality Testing 

It is important to test the water in which the animals live on a regular basis. Coliform bacterial counts 

are used to monitor the efficiency of the filtration system to eliminate potentially harmful bacteria. 

Coliform counts should be done at least once per week and more frequently if there are very large or 

multiple animals utilizing the pool. While coliform numbers may be described as Most Probable 
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Number (MPN) per 100 ml, a more accurate method of measuring coliforms is to determine the total 

coliform count, or the fecal coliform count. 

Temperature of the water is especially important if the animal lacks the ability to thermoregulate. 

Water may require heating or chilling to aid debilitated animals in their ability to maintain optimal 

body temperature, although debilitated pinnipeds are likely to haul out, in such case the water 

temperature becomes less important. Water temperature regulation is not feasible in open water pens, 

but keeping track of the water temperature in sea pens may aid the staff in making husbandry 

decisions. If coliform numbers or the water temperature becomes too high in any system, measures 

must be taken to correct the problem in a timely manner. A partial-to-total water change may be 

necessary to correct the problem in a closed or semi-closed system. If the coliform counts are 

considered too high in sea or bay pens, efforts should be made to circulate clean sea water through the 

pens using pumps, paddles or other methods of moving water. 

Chemicals added to the water may damage eyes and skin and must be monitored daily. Salinity, 

when utilized for rehabilitating pinnipeds, may also have an impact on the health of the skin and eyes, 

as well as the comfort level of the animal, and should be monitored regularly. Emergency chemicals 

should be on hand such as sodium thiosulfate in case of the accidental hyperchlorination of a system. 

2.3.1 Water Quality Tests 

MINIMUM STANDARD 

• Measure coliform growth weekly, unless pools are dumped and filled daily. 

• Total coliform counts must not exceed 500 per 100 ml or a MPN of 1000 coliform bacteria per 

100 ml water. Fecal coliform counts are not to exceed 400 per 100 ml. 

• If the above tests yield results that exceed the allowable bacterial count, then two subsequent 

samples must be taken to repeat the test(s) where the level(s) is/are exceeded. The second sample 

is to be taken immediately after the initial test result, while the third sample would be taken 

within 48 hours of the initial test. 

• If the averaged value of the three test results still exceeds the allowable bacterial counts, the 

condition must be corrected immediately or the animals moved to a contingency facility. 

• Maintain pH between 6.5 and 8.5. 

• Maintain the temperature of the water so that it falls within parameters appropriate for the 

species, generally between 50-80o

F. 
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• Measure oxidant levels in systems which require use of a chemical disinfectant and/or ozone in 

the system (for closed systems). 

RECOMMENDED 

• Maintain pH between 7.2 to 8.2. 

• Total Coliforms with blanks and controls, fecal Coliform, fecal Strep, and yeast count performed 

weekly or as needed. 

2.3.2 Frequency of Testing in Closed, Semi-open, or Open Systems 

MINIMUM STANDARD 

• Measure water temperature, pH, salinity (if applicable), chemical additives (if applicable) daily in 

all pools. 

• Measure coliform counts weekly; and more frequently at the discretion of the attending 

veterinarian. 

RECOMMENDED 

• If ozone systems are used, measure ozone levels regularly in the animal pools. Ozone levels shall 

not exceed 0.02 mg/liter. 

• Test source and discharge water at least once per day (more frequently for “flow through” 

systems). 

• Maintain records for tests with time, level and results – reviewed and signed monthly by the 

attending veterinarian or animal care supervisor. 

2.3.3 Chemical Additives 

Total chlorine = Free chlorine + combined chlorine. 

MINIMUM STANDARD

• Maintain total chlorine below 1.5 ppm, where the combined chlorine shall not exceed 50% of the 

total chlorine. 

• All additives must be recorded. 

• pH may be adjusted chemically – for example – pH may be raised with sodium carbonate, or soda 

ash; or lowered with HCl or CO2; but not added in a manner that could cause harm or discomfort 

to the animals. 
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• Maintain MSDS information and signage as well as appropriate handling equipment for the 

addition of chemicals. 

2.3.4 Water Circulation 

The amount of water turnover through the filtration system in a closed or semi-open system is 

important to maintain water quality by removing organic waste and particulate matter. Likewise the 

amount of water movement through an open water pen is also important in the maintenance of water 

quality. Generally, adequate tidal action will result in the equivalent of two complete water changes 

per day. 

MINIMUM STANDARD 

• Maintain sufficient turnover of water through the filtration system in closed or semi-open systems 

to keep the water quality at or above acceptable limits, with a minimum of two complete water 

changes per day. 

• Ensure methods for moving water (water paddles, pumps, spray devices) are available to aerate 

and move water in open water pens with insufficient flow of tides or water through the 

enclosures. These methods should be sufficient to provide the equivalent of two water changes 

per day. 

RECOMMENDED 

• A minimum full water turnover rate of every four hours for each pool in closed or semi-open 

systems. 

2.3.5 Salinity 

Pinnipeds under rehabilitation may be housed in fresh water. However salinity may play a part in eye 

health, may enhance wound healing, or may be desirable in some other instances. In some cases 

animals will drink fresh water which may aid in rehydration. Placing animals in water of appropriate 

salinity shall be left to the discretion of the animal care supervisor and staff in consultation with the 

attending veterinarian. 

2.3.6 pH 

MINIMUM STANDARD 

• pH shall be held in a range between 6.5 to 8.5. 
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RECOMMENDED 

• Maintain pH between 7.2 to 8.2. 

2.3.7 Water Temperature 

MINIMUM STANDARD 

• Hold water temperatures within the normal habitat temperature range for the species under 

rehabilitation or as authorized in writing by the attending veterinarian. 

• Provide methods to heat and maintain warm water environments for species that require it, or for 

debilitated or critically ill individuals that are incapable of maintaining appropriate body 

temperature. 

• Monitor temperature of water being heated or cooled. 

2.4 Quarantine 

Pinnipeds brought to a rehabilitation facility have no medical history and may carry diseases 

communicable to other marine mammals, other animals, or humans. Likewise, these animals are 

often debilitated and may suffer from a variety of illnesses which may compromise their immune 

systems making them susceptible to diseases from other animals. Quarantine areas must be available 

and proper biosecurity protocols must be in place for all incoming animals at rehabilitation facilities. 

Direct contact between the general public and pinnipeds undergoing rehabilitation should be avoided 

because of the zoonotic risk of some organisms carried by marine mammals. There have been 

documented cases of Brucella, Leptospira, Mycoplasma (Seal Finger), San Miguel Sea Lion Virus, 

Influenza A, and Sealpox, being passed from pinnipeds to humans. 

Listed on the following website are numerous other potentially zoonotic marine mammal pathogens 

(see http://www.vetmed.ucdavis.edu/whc/mmz/). See also: 2004 UC Davis Wildlife Health Center 

Report for the Marine Mammal Commission – Assessment of the Risk of Zoonotic Disease 

Transmission to Marine Mammal Workers and the Public: Survey of Occupational Risks. 
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2.4.1 Prevention of Animal to Animal Transmission of Diseases 

MINIMUM STANDARD 

• Quarantine all new animals in a separate dedicated quarantine area and provide pens/pools that 

can be isolated with the use of dividers, tarps, or physical space from the rest of the animal 

housing areas. Animals that are admitted in groups may be quarantined together. 

• Provide dividers between pens and pools that prevent washdown or splash from moving from one 

pool or pen to another. 

• Use dedicated protective clothing for personnel- including gloves, eye shields, safety glasses, 

and/or eye wash stations. 

• Use foot baths, glove baths, and methods to disinfect clothing between handling animals within 

quarantine area and outside of quarantine area. 

• Maintain equipment and tools strictly dedicated to the quarantine area or thoroughly disinfect. 

• Provide sufficient space or solid-surfaced barriers between animal enclosures to prevent direct 

contact between animals. 

• Provide sufficient air turnover in indoor facilities to prevent transmission of disease. Air turnover 

should be enough to prevent build-up of heat and provide a method of bringing fresh air into the 

facility. There should be sufficient venting or openings to allow movement of air throughout the 

facility. 

• Implement specific quarantine and sanitation procedures to prevent transmission of disease 

through fomites (e.g., clothing, equipment): 

o Thoroughly clean and disinfect buckets, hoses, scales, transport equipment, and cleaning 

equipment that is moved between animal areas to prevent transmission of pathogens via 

fomites. 

• Place open water pens so effluent is not near water intake. 

• Require evaluation and written veterinary approval before placing animals together after 

quarantine period has been met. 

RECOMMENDED 

• Provide separate air handling system in indoor facilities. 

• Separate entries to quarantine areas with no crossover with the rest of the facility. 

• Clean and disinfect quarantine areas between uses. 
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2.4.2 Prevention of Domestic Animal to Marine Mammal Transmission of 

Disease 

• Ensure appropriate fencing and placement of holding pens to prevent direct contact between 

rehabilitating pinnipeds and domestic animals. 

• Prohibit personal pets within outermost perimeter of facility. 

• Require that specific quarantine and sanitation procedures are taken to prevent transmission of 

disease through fomites such as clothing and equipment. 

• Use dedicated carriers for pinnipeds – carriers should not be used for other mammals or birds 

unless they are thoroughly scrubbed and disinfected between uses. 

2.4.3 Prevention of Wild Animal to Marine Mammal Transmission of 

Disease 

• Ensure perimeter fencing will deter wildlife from entering the rehabilitation premises. 

• Provide rodent control on the premises. 

• Ensure net pens and lagoon areas have sufficient secondary fencing to keep wild mammals from 

coming in direct contact with the animals housed in the net pens. 

2.4.4 Prevention of Marine Mammal to Domestic Animal Transmission of 

Disease 

• Provide appropriate perimeter fencing. 

• Require animal personnel to change contaminated clothing and/or disinfect before leaving the 

rehabilitation premises. 

• Require that specific quarantine and sanitation procedures are taken to prevent transmission of 

disease through fomites such as clothing and equipment. 

• Follow appropriate release guidelines. 

2.4.5 Prevention of Stranded Marine Mammal to Captive Marine Mammal 

Transmission of Disease 

• Train volunteers and staff to follow appropriate quarantine protocols. 

• Establish quarantine protocols that take into consideration the changing status of the stranded 

animal. 

• Establish traffic flow so that volunteers or staff working with stranded animals do not 

inadvertently travel into a collection animal area. 
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• Establish decontamination protocols before volunteers or staff members exposed to stranded 

animals may enter a collection animal area. 

• Establish separate restrooms, showers, changing rooms, food preparation areas, etc. for staff and 

volunteers working with rehabilitating vs. collection animals. Food for rehabilitating animals 

may be prepared in the collection animal kitchen and taken to the rehabilitation animal area, 

however any bucket, feed implement or other item must be thoroughly disinfected before it may 

return to the collection animal area. 

2.4.6 Methods to Reduce Spread of Disease from Animals Housed in 

Open Sea/Bay Pen Systems 

• Place pens in a secluded area where wild animals and marine mammals are unlikely to come into 

direct contact with the animals housed in the sea/bay pens. 

• Place a second set of perimeter nets 30 feet from the sea/bay pens to prevent direct contact with 

wild marine mammals. Nets should be sufficiently rigid to prevent entanglement by mammals or 

fish. 

• Do not place sea/bay pens within 1000 meters any major outflow sewage treatment plants and 

consider the flow direction or current from these major outflows. 

• Place the sea/bay pens 500 meters and downstream from water intake pipes that bring water into 

facilities that house marine mammals. 

• Place pens in an area where there is ample flow-through of tides/currents. 

• Ensure the pens are of sufficient size to minimize biomatter build-up. Each pinniped should be 

housed in a pen that has a minimum depth of half of their body length, and a minimum horizontal 

dimension of two full body lengths. 

• Avoid overcrowded pens. Animals may fight with each other when housed too closely together. 

• Have equipment to pump or aerate the water in pens that do not have sufficient tidal action to 

ensure a minimum of two complete water changes per day. 

• Place pens in areas where there is sufficient depth to enhance water circulation and reduce 

pathogen build-up. Weekly coliform testing will determine if pathogen build-up exists. Water 

circulation may be enhanced using water paddles. 

• Place quarantine pens such that tidal action or underwater currents will not flow from quarantine 

pens through sea pens housing healthy animals. 
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2.4.7 Evaluation Requirements before Placing Marine Mammals 

Together 

• CBC/Chemistries, appropriate cultures, physical examination before moving animals out of 

quarantine area and at the discretion of the attending veterinarian. 

• Review current NMFS recommendations on diseases of concern and reportable disease such as 

morbillivirus. 

• Consider screening for morbillivirus, herpes virus, brucellosis, leptospirosis, and toxoplasmosis

utilizing the most current diagnostic tests available and at the discretion of the attending 

veterinarian. 

• If animals are part of a UME, then screening for diseases must be more thorough and in direct 

coordination with NMFS and the UME On-site Coordinators. 

• Have contingency plan for animals that are actively infected with or carriers of a reportable 

disease such as brucellosis, leptospirosis, toxoplasmosis, herpes virus, and morbillivirus. 

2.4.8 Zoonotic Considerations 

• Restrict public access and direct contact with pinnipeds due to zoonosis potential and public 

health hazard of untrained individuals interacting with sick and injured marine mammals. 

• Train staff and personnel about how to prevent contracting zoonotic diseases (Occupational and 

Safety Information for Marine Mammal Workers http://www.vetmed.ucdavis.edu/whc/mmz/). 

• Train staff and personnel working directly with stranded pinnipeds how to recognize symptoms 

of zoonotic disease. 

• Train staff the basics of sanitation and properly handling contaminated equipment. 

• Provide appropriate safety equipment, as reasonable, such as protective clothing, eye protection 

and face masks to all staff who may be exposed to zoonotic diseases. 

• Provide eye flushing stations as used with HAZMAT or normal saline bottles to irrigate the eyes. 

• Staff with open wounds shall not handle animals carrying potentially infectious diseases 

 without appropriate precautions to protect their wound(s). 

2.4.9 Pre-Release Guidelines 

• Pre-release health screens and serologic requirements are determined by the NMFS Regional 

Stranding Coordinator and the Marine Mammal Health and Stranding Response Program (see 

NMFS/FWS Best Practices for Marine Mammal Stranding Response, Rehabilitation, and Release 

– Standards for Release). 
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2.5 Sanitation 

2.5.1 Primary Enclosure Sanitation 

MINIMUM STANDARD 

• Remove animal and food waste in areas other than the rehabilitation pool from the rehabilitation 

enclosure at least daily, and more often when necessary to prevent contamination of the marine 

mammals contained therein and to minimize disease hazards. 

• Remove particulate animal and food waste, trash, or debris that enter rehabilitation/exercise pens 

or pools at least once daily, but as often as necessary to maintain water quality and to prevent 

increased health hazards to the marine mammals that use the pools. 

• Remove trash and debris from pools as soon as it is noticed, to preclude ingestion or other harm 

to the animals. 

• Clean the walls and bottom surfaces of the rehabilitation/exercise pens and pools as often as 

necessary to maintain a clean environment and proper water quality. 

• Ensure appropriate disinfectants mixed to recommended dilutions are utilized to clean pens, 

equipment, utensils, and feed receptacles and to place in foot baths. These disinfectants should 

have both bacteriocidal and virocidal qualities. 

• Rotate disinfectants on a regular basis to prevent bacterial resistance. 

• Prevent animals from coming in direct contact with disinfectants or aerosol from spray or 

cleaning hoses (i.e., water splashed from floor). 

RECOMMENDED 

• Empty and allow pools to dry once each year but dry and hyperchlorinate pool bottoms and walls 

and haul-out areas after each use by sick pinnipeds. 

2.5.2 Sanitation of Food Preparation Areas and Food Receptacles 

• Use separate food preparation areas and supplies for rehabilitation vs. collection animals. 

• Clean food containers such as buckets, tubs, and tanks, as well as utensils, such as knives and 

cutting boards, or any other equipment which has been used for holding, thawing or preparing 

food for marine mammals after each feeding, and sanitize at least once a day. Equipment should 

be cleaned with detergent and hot water, sanitized and dried before reuse. 

• Clean kitchens and other food handling areas where animal food is prepared after every use, and 

sanitize at least once weekly using standard accepted sanitation practices. 
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• Store substances such as cleaning and sanitizing agents, pesticides and other potentially toxic 

agents in properly labeled containers away from food preparation areas. 

• Post MSDS “right to know” documents for staff utilizing cleaning and animal treatment 

chemicals and drugs. 

2.6 Food, Handling, and Preparation 

During rehabilitation food for marine mammals shall be wholesome, palatable, free from 

contamination, and of sufficient quantity and nutritive value to allow the recovery of the animals to a 

state of good health. Live fish may be fed during rehabilitation but preferences should be given to 

native prey species. Live fish may contain parasites which could infect compromised animals. 

Feeding regimens should be tailored to enhance weight gain for underweight animals or growing 

pups, and should simulate natural patterns in terms of frequency and quantity to the extent possible 

while following a prescribed course of medical treatment. Most pinnipeds feed several times during a 

given day 

2.6.1 Diets and Food Preparation 

MINIMUM STANDARD 

• Prepare the diets with consideration for age, species, condition, and size of marine mammals 

being fed. 

• Feed pinnipeds a minimum of twice a day, except as directed by a qualified veterinarian or when 

following professionally accepted practices. 

• Diets reviewed by a nutritionist, attending veterinarian, or the animal care supervisor. 

• Train staff to recognize good and bad fish quality. 

• Feeding live fish may be required for release determination. See NMFS /FWS Best Practices for 

Marine Mammal Stranding Response, Rehabilitation, and Release – Standards for Release for 

more information regarding feeding live fish. 

• Food receptacles should be cleaned and sanitized after each use. Food preparation and handling 

should be conducted so as to minimize bacterial or chemical contamination and to ensure the 

wholesomeness and nutritive value of the food. 

2.6.2 Food Storage and Thawing 

• Frozen fish or other frozen food shall be stored in freezers which are maintained at a maximum 

temperature of 0o

 F (-18 o C). 
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• The length of time food is stored and the method of storage, as well as the thawing of frozen food 

should be conducted in a manner which will minimize contamination and which will assure that 

the food retains optimal nutritive value and wholesome quality until the time of feeding. 

• Freezers should only contain fish for animal consumption. Human food or specimens should not 

be placed in the fish freezer. 

• Experienced staff should inspect fish upon arrival to ensure there are no signs of previous 

thawing and re-freezing, and check temperature monitoring devices in the transport container. 

The fish shipment should be refused, or fish should be discarded if temperature fluctuations 

occurred during transport. 

• Freezers shall be of sufficient size to allow for proper stock rotation. 

• All foods shall be fed to the marine mammals within 24 hours following the removal of such 

foods from the freezers for thawing. 

• If the food has been thawed under refrigeration it must be fed to marine mammals within 12 

hours of complete thawing. 

• When fish is thawed in standing or running water, the coldest available running water must be 

used to prevent excess bacterial growth. 

• To ensure optimal quality of the fish, and to prevent bacterial overgrowth, do not allow fish to 

reach room temperature or sit in direct sunlight. 

• The thawed fish shall be kept iced or refrigerated until a reasonable time before feeding. This 

time will vary with ambient temperature. 

• Prepared formula should be fed immediately or refrigerated and fed to the marine mammals 

within 24 hours of preparation. Formula, once heated to an appropriate temperature for a feed, 

shall be discarded if it is not consumed within one hour. 

RECOMMENDED 

• Calculate kilocalories of each type of fish or food items fed to each animal daily. 

• Conduct food analysis for protein, fat and water content of each lot of fish used. Analysis from 

fish supplier may be used, and a copy should be maintained on site. 

• Calculate composition of each diet routinely used. 
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2.6.3 Supplements 

MINIMUM STANDARD 

• Each animal shall receive appropriate vitamin supplementation which is sufficient and approved 

in writing by the attending veterinarian. 

• Salt supplements shall be given to pinnipeds housed in fresh water as necessary and as approved 

by the attending veterinarian. 

2.6.4 Feeding 

Food, when given to each marine mammal individually or in groups, must be given by an employee 

or trained personnel who has the necessary training and knowledge to assure that each marine 

mammal receives an adequate quantity of food to maximize its recovery or maintain good health. 

Such personnel are required to recognize deviations in each animal being rehabilitated such that food 

intake can be adjusted accordingly. 

2.6.5 Public Feeding 

MINIMUM STANDARD 

• Public feeding is not allowed for animals that are being rehabilitated. 

• Feeding must be conducted only by qualified, trained rehabilitation staff members. 

2.6.6 Feed Records 

MINIMUM STANDARD 

• Maintain feed records for each individual animal noting the individual (not an estimate) daily 

consumption by specific food type. 

• If animals are fed in groups then group feed records shall be maintained and together with daily 

husbandry notes and weekly weight records ensure evidence of sufficient feed intake. 

• Weigh food before and after each feeding individuals and groups and the record the amount 

consumed. 

• Weigh the animal as practical, keeping in mind that obtaining the weight of the animal may 

stressful. 

• If weighing the animal is not an option, obtain the girth measurement at the level of the axilla if 

possible. 
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2.7 Veterinary Medical Care 

All rehabilitation facilities shall have an attending veterinarian. The attending veterinarian is critically 

involved in making decisions regarding medical care as well as housing and husbandry of resident 

and newly admitted patients. 

2.7.1 Veterinary Experience 

MINIMUM STANDARD 

The attending veterinarian shall: 

• Assume responsibility for diagnosis, treatment, and medical clearance for release or transport of 

marine mammals in rehabilitation (50 CFR 216.27). 

• Ability to provide a schedule of veterinary care that includes a review of husbandry records, 

visual and physical examinations of all the marine mammals in rehabilitation, and a periodic 

visual inspection of the facilities and records. 

• Be available to examine animals on a regular schedule and emergency basis. 

• Be available to answer veterinary questions on a 24 hour basis. 

• Have marine mammal experience or be in regular consultation with a veterinarian who has 

marine mammal experience and have access to a list of expert veterinarians to contact for 

assistance. 

• Have an active veterinary license in the United States (means a person who has graduated from a 

veterinary school accredited by the American Veterinary Medical Association Council on 

Education, or has a certificate issued by the American Veterinary Graduates Association's 

Education Commission for Foreign Veterinary Graduates), or has received equivalent formal 

education as determined by NMFS Administrator (adapted from the Animal Welfare Act 

Regulations 9 CFR Ch. 1). 

• Have the skills to be able to draw blood and give injections to the species most commonly 

encountered at the rehabilitation center. 

• Facility management should have contingency plan for veterinary backup. 

• Have the appropriate registrations and licenses (e.g., registered with the Drug Enforcement 

Administration for handling controlled substances) to obtain the necessary medications for the 

animals housed at that rehabilitation facility. 

• Be able to conduct a full post-mortem exam on all species of pinnipeds treated at the facility. 

• Be knowledgeable and able to perform pinniped euthanasia. 
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• Be knowledgeable about species-specific pharmacology. 

• Must certify in writing that animals are fit for transport. 

• Ability to write and submit timely disposition recommendations for marine mammals in 

rehabilitation. 

• Be knowledgeable of marine mammal zoonotic diseases. 

RECOMMENDED 

All of the above plus: 

• Membership in the International Association for Aquatic Animal Medicine. 

• Complete a course which offers basic medical training with marine mammals such as Seavet, 

Aquavet, or MARVET. 

• Have at least one year of clinical experience outside of veterinary school. 

• Have access to a current version of the “Handbook of Marine Mammal Medicine” Have basic 

hands-on veterinary experience with the species most frequently rehabilitated at the facility. 

• Be full time employee or the contract veterinarian of record at facilities managing over 50 

pinniped cases per year (i.e., live and dead). 

2.7.2 Veterinary Program 

MINIMUM STANDARD 

• Veterinary care for the animals must conform with any State Veterinary Practice Act or other 

laws governing veterinary medicine which applies to the state in which the facility is located.

• Standard operating procedures should be reviewed and initialed by the attending veterinarian or 

the animal care supervisor annually and/or whenever the document is changed or updated. This 

document may be reviewed by NMFS as part of the NMFS Stranding Agreement or as part of 

inspections. 

• Staff caring for animals should be sufficiently trained to assist with veterinary procedures under 

the direction of the veterinarian and the rehabilitation facility should maintain at least one Animal 

Care Supervisor who is responsible for overseeing prescribed treatments, maintaining hospital 

equipment, and controlling drug supplies. The person should be adequately trained to deal with 

emergencies until the veterinarian arrives, be able to direct the restraint of the animals, be 

responsible for administration of post-surgical care, and be skilled in maintaining appropriate 

medical records. It is important that the animal care supervisor should communicate frequently 
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and directly with the attending veterinarian to ensure that there is a timely transfer of accurate 

information about medical issues. 

• Veterinary decisions shall be based on “best practices” (i.e., based on informed opinions and 

expertise of veterinarians practicing marine mammal medicine). 

• A schedule of veterinary care which includes a review of husbandry records, visual and physical 

examinations of the animals, and a visual inspection of the facilities should be implemented

• A health and safety plan for the staff shall be written and accessible at all times. It shall be 

reviewed by the attending veterinarian or the animal care supervisor annually or as prescribed by 

the NMFS Stranding Agreement. Also, it may be beneficial to consult with an occupational health 

medical professional when developing these plans. All animal care staff will be familiar with the 

plan. The plan shall include protocols for managing bite wounds. 

The following reports may be requested annually by NMFS as required under the NMFS Stranding 

Agreement or as a part of inspections 

• SOP reviews 

• Health and Safety Plan reviews 

• Animal acquisitions and dispositions 

• NOAA Form 89864, OMB#0648-0178 (Level A data) 

• NOAA Form 89878, OMB#0648-0178 (Marine Mammal Rehabilitation Disposition Report) 

• Case summaries for any rehabilitation performed at a facility, including narrative descriptions of 

the cases as well as spreadsheets of treatments, blood values, etc. 

2.8 Laboratory Tests and Frequency of Testing 

Specific requirements for tests will be issued by the NMFS stranding coordinator (or UME Onsite 

Coordinator) in each region as outlined in the Marine Mammal Health and Stranding Response 

Program for release determinations, surveillance programs and UME investigations. Routine 

diagnostic sampling and testing protocols will be determined by the attending veterinarian. NMFS 

must be provided adequate time and information including a veterinary certificate of health before an 

animal is released as directed in 50 CFR 216.27 (see NMFS/FWS BEST PRACTICES for Marine 

Mammal Stranding Response, Rehabilitation, and Release – Standards for Release ). 
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MINIMUM LABORATORY TESTING

• CBC/Serum Chemistry- For most cases, all animals shall have a minimum of two blood samples 

drawn for CBC with differential and serum chemistry; upon admission and prior to release (see 

NMFS/FWS Best Practices for Marine Mammal Stranding Response, Rehabilitation, and Release 

– Standards for Release). If duration of rehabilitation is shorter than a week, one blood workup 

may suffice and is at the attending veterinarian’s discretion. 

• Fecal analysis for parasites- Fecal tests for parasites shall be run upon admission of each animal 

at the discretion of the attending veterinarian. 

• Serology as necessary for release determination based on direction of the NMFS stranding 

coordinator and the Marine Mammal Health and Stranding Program each year and for additional 

clinical diagnosis as deemed appropriate by the attending veterinarian. 

• If serology is positive for pathogens of concern NMFS must give final sign off before animal is 

released. 

• Measure body weight, and length upon admission, and within one week of release/placement. 

Measure girth when possible, or whenever a scale is not available to measure weight. 

• The attending veterinarian or a trained staff member shall perform a necropsy on every animal 

that dies within 24 hours of death if feasible. If necropsy is to be performed at a later date 

(ideally no longer than 72 hours postmortem), the carcass should be stored appropriately to delay 

tissue decomposition. 

• Carcass disposal shall be handled in a manner consistent with local and state regulations. 

• Perform histopathology on select tissues from each animal that dies at the discretion of the 

attending veterinarian. A complete set of all major tissues should be evaluated if the animal dies 

of an apparent infectious disease process. 

• Culture and other diagnostic sampling shall be conducted as directed by the attending veterinarian 

to determine the cause of stranding or death. 

• Contact NMFS for additional laboratory test requirements in all cases of unusual mortality 

outbreaks or disease outbreaks. More complete testing may be required for diseases of concern. 

• For cases involving release decisions, unusual mortality investigations, or surveillance programs, 

serologic assays may only go to labs that have validated tests approved by NMFS, especially for 

release decisions or determinations. Guidance will be provided by the NMFS Stranding 

Coordinators or UME Onsite Coordinator. 

• Notify the NMFS Stranding Coordinator of learning of any diseases of concern (e.g., emerging, 

reportable, and/or zoonotic diseases) that are detected and/or confirmed that could be a potential 
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hazard for public health or animal health (NMFS will provide guidance on reportable diseases as 

it becomes available). 

• NMFS must be provided adequate time and information (including veterinary certificate of 

health) before the animal is released in all cases as directed in 50 CFR 216.27 (see NMFS 

Standards for Release). This information is required under 50 CFR 216.27(a) and must be 

submitted 15 days prior to release unless advanced notice is waived by the NMFS Regional 

Administrator. Guidance on the waivers is provided in the NMFS/FWS Best Practices for Marine 

Mammal Stranding Response, Rehabilitation, and Release – Standards for Release. 

 RECOMMENDED 

• CBC/Serum Chemistry with electrolytes on admission, within the week prior to release, and 

every other week during rehabilitation if restraint for sampling is not detrimental to the health of 

the animal. 

• More frequent blood sampling at the discretion of the veterinarian. 

• Weight measured on admission, just before release, and weekly for growing pups and 

underweight animals. 

• Weights should be measured monthly for all animals unless the stress of capturing the animal to 

weigh it outweighs the benefits of the data. 

• Complete necropsy performed by a veterinarian or a pathologist within 24 hours of death. 

• Full histopathology done on tissues from each animal that dies of apparent infectious disease. 

• Bank 1cc of serum per blood draw in –80oF freezer. 

2.9 Record Keeping and Data Collection 

Record keeping is an essential part of the rehabilitation process. Not only do accurate and complete 

medical records for each stranded pinniped allow the staff to provide consistent and optimal care for 

each animal, but retrospective records help scientists and veterinarians make better evaluations on 

how to treat individuals. 
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Record Keeping 

MINIMUM RECORDS 

• Record and report “Level A”, and disposition reports as advised by Regional Coordinator and 

Marine Mammal Rehabilitation Disposition Report (NOAA 89-878, OMB #0648-0178) as in 

accordance with the NMFS Stranding Agreement. 

• Maintain and update individual medical records daily on each animal at the rehabilitation center. 

• Individually identify each animal with unique identifier 

• Keep an accurate description of the animal, including identification/tag number, date and location 

of stranding, sex, weight, and length at stranding. 

• Subjective, objective, assessment and plan (SOAP) based records are preferred 

• Include food intake and medication administered to each animal in the records each day. 

• Weight 

a. Recorded weekly for underweight pinnipeds or pups, and more often if the attending 

veterinarian feels it is necessary to properly care for the animal. 

b. Recorded on admission and release for larger pinnipeds. 

• Record all treatments, blood work, test and results and daily observations in the medical records. 

• Maintain individual medical records for each animal. Medical records remain on site where the 

animal is housed and are available for NMFS review upon request as stated in the NMFS 

Stranding Agreement. 

• Hold medical records for a minimum of 15 years on site. 

• Maintain up to date water quality records. 

• Maintain life support system maintenance records. 

• Maintain records of water quality additives.

RECOMMENDED RECORD KEEPING 

All of the above plus: 

• Full set of standard morphometrics prior to release.

• Photographic documentation of animals with significant lesions, identifying marks.

• Caloric value of daily food intake calculated and recorded for each animal. 

• Daily weight of underweight pups. Larger species, where pups exceed 50 kg, may require 

obtaining weights less frequently.
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• Monthly weights of larger pinnipeds (where the stress of capture to weigh does not adversely 

affect the rehabilitation efforts).

• Maintain food acquisition and analysis records.

• Maintain “paper copy” archive of required NMFS records.

2.9.1 Data Collection 

MINIMUM STANDARD 

• Written documentation of the medical history, food and observation records must be kept. 

• NMFS Required Forms to be completed in writing or submitted electronically in the NMFS 

National Marine Mammal Stranding Database as prescribed in the NMFS Stranding Agreement: 

a. NOAA Form 89864, OMB#0648-0178 (Level A data) 

b. NOAA Form 89878, OMB#0648-0178 (Marine Mammal Rehabilitation Disposition Report). 

RECOMMENDED 

• Computerized documentation with hard copies. 

• Ability to network with other institutions. 

• Maintain real-time accessible compiled comparative data. 

2.10 Euthanasia 

• Each institution must have a written euthanasia protocol signed by the attending veterinarian. 

• Persons administering the euthanasia must be knowledgeable and trained to perform the 

procedure. 

• Maintain a list of individuals authorized to perform euthanasia signed by the veterinarian. 

• Euthanasia shall be performed in a way to minimize distress in the animal. 

• Refer to resources such as the American Veterinary Medical Association Panel Report on 

Euthanasia, the CRC Press Handbook of Marine Mammal Medicine and American Association 

for Zoo Veterinarians Guidelines for Euthanasia of Nondomestic Animals. 

• Appropriate drugs for euthanasia in appropriate amounts for the largest species admitted to the 

facility shall be maintained in stock on site in an appropriate lockbox or under the control of a 

licensed veterinarian with a current DEA license. 

• Drugs for euthanasia shall be kept with an accurate inventory system in place. 

• DEA laws and regulations and State Veterinary Practice Acts must be followed when using 

controlled drugs 
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• NMFS may request this information (protocols and DEA number) as part of the NMFS Stranding 

Agreement. 

2.11 Health and Safety for Personnel 

There shall be a health and safety plan on site at each rehabilitation facility that identifies all health 

and safety issues that may be factors when working closely with wild marine mammals. The plan 

should identify all potential zoonotic diseases as well as including safety plans for the direct handling 

of all species and sizes of pinnipeds seen at that facility. Rehabilitation facilities are encouraged to 

comply with Occupational Safety and Health Administration regulations. 

MINIMUM STANDARD 

• Identify all potential zoonotic diseases in a written document available to all personnel. 

• Include safety plans for the direct handling of all species and sizes of pinnipeds seen at that 

facility. 

• Include safety plan for dealing with handling any untreated discharge water. 

2.12 Contingency Plans 

Contingency plans shall be in place at each facility and may be required by NMFS as part of the 

NMFS Stranding Agreement. NMFS may require approved variances or waivers prior to planned 

projects such as construction. These plans should address in detail the operation of the facility and 

care of the animals under the following conditions: 

• Inclement weather plan, including a hurricane/big storm plans where appropriate. 

• Construction in the vicinity of the animal rehabilitation pens or pools. 

• Power outages, including plans of how to maintain frozen fish stores and life support systems. 

• Water shortages. 

• “Acts of God” plan which may include floods, earthquakes or other unpredictable problems 

known to occur on occasion in the region where the facility is located. 

2.13 Viewing 

NMFS Regulation, U.S.C. 50 CFR 216.2(c)(5) states that marine mammals undergoing rehabilitation 

shall not be subject to public display. The definition of public display under U.S.C. 50 CFR is “an 

activity that provides opportunity for the public to view living marine mammals at a facility holding 
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marine mammals captive”. Only remote public viewing or distance viewing should be allowed and 

only when there is no possible impact of the public viewing on the animals being rehabilitated. 

There is a regulatory requirement for a variance or waiver by NMFS for facilities planning to offer 

public viewing of any marine mammal undergoing rehabilitation. 

2.14 Training and Deconditioning Behaviors 

Basic behavioral conditioning of wild pinnipeds for husbandry and medical procedure may be 

warranted during rehabilitation as long as every effort is made to limit reinforced contact with 

humans. Such conditioning may reduce stress for the animal during exams and acquisition of 

biological samples. Conditioning may assist with appetite assessment and ensuring that e each animal 

in a group receives the appropriate amount and type of diet and medications. In some cases, extensive 

contact with humans, including training, may benefit resolution of the medical case by providing 

mental stimulation and behavioral enrichment, and may facilitate medical procedures. The relative 

costs and benefits of training should be evaluated by the staff veterinarian, and the likelihood of 

contact with humans following release should be considered. 

Behavioral conditioning of pinnipeds must be done for the shortest time necessary to achieve 

rehabilitation goals and is to be eliminated prior to release such that association of food rewards with 

humans is diminished. If an animal has become accustomed to hand-feeding the animal may 

approach humans after release. Therefore, these behaviors should be deconditioned before the 

animals can be considered for release. Most behaviors will extinguish through lack of reinforcement, 

but some may require more concentrated efforts. 

Training for research that is above and beyond the scope of normal rehabilitation practices can be 

approved on a case-by case basis under a NMFS scientific research permit. An exception can be 

made if the attending veterinarian, facility, and NMFS officials all agree that the research will not be 

detrimental to the animals' health and welfare and will not impede their ability to be successfully 

released back to the wild. 

2.15 References 

Langman VA, Rowe M, Forthman D, Whitton B, Langman N, Roberts T, Kuston K, Boling C, and 

Maloney D. 1996. Thermal Assessment of Zoological Exhibits I: Sea Lion Enclosure at the Audubon 

Zoo. Zoo Biology 15:403-411. 
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Rehabilitation Facilities February 2009 

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3. Frequently Asked Questions 

Why are there two sets of standards, “minimum” and “recommended”, in the facilities 

guidelines? 

The thought behind the two sets of guidelines was to establish a bare minimum standard which every 

facility should have to meet in order to rehabilitate either pinnipeds or cetaceans. The 

“recommended” standards are standards considered more ideal to help maximize the success of the 

rehabilitation effort, and to minimize the potential spread of disease. Many facilities exceed the 

recommended standard. 

Facilities that just meet the minimum standards may wish to improve their facility over time. The 

Facilities Guidelines could serve as a method of justifying and helping to secure Prescott Funds or 

other funding to make improvements to bring a facility up to the recommended standards. 

Why are there separate standards for pinnipeds and cetaceans? 

While many aspects of rehabilitating cetaceans and pinnipeds that are the same, there are likewise 

many significant differences. Water quality, pool space and design, and handling debilitated animals 

are examples of the bigger differences between facility design and equipment required for 

rehabilitation of these animals. Rehabilitation of cetaceans requires more expensive facilities, as 

there must be larger, deeper pools available, salt water systems, and more elaborate filtration in 

closed system situations. While some facilities have adequate equipment and personnel to 

rehabilitate pinnipeds, they may not meet the standards required for the rehabilitation of cetaceans. 

Having two sets of guidelines allows NMFS the flexibility of issuing agreements specific to the types 

of animals that may be rehabilitated at each facility. 

Many of the standards listed appear to be directly from the AWA standards. Why don’t you 

just state that the facilities will meet all of the AWA regulations? What if the AWA regulations 

change? 

AWA regulations have specific engineering standards to cover captive marine mammals. These 

standards for pool size and depth are based on captive adult-sized animals. The majority of pinnipeds 

admitted to most rehabilitation facilities are pups, juveniles, and sub-adults, and because they are not 

going to be permanent members of a collection, pool size may be smaller than the minimum sizes 
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Rehabilitation Facilities February 2009 

3-2 

stated in the AWA regulations. Cetacean facility guidelines minimum pool sizes are closer to the 

AWA regulations in pool size, but not identical, as these animals are not considered to be permanent 

residents. 

AWA regulations may change, however these Facilities Guidelines were created with the 

consideration that animals being rehabilitated are not permanent residents of the facility. Therefore 

even if AWA regulations change, it is likely, the Stranding Network Facilities Guidelines will remain 

the same. Facilities Guidelines apply to the wild animals held by participants of the stranding 

network, whereas the AWA regulations refer to captive animals owned by the licensees. 

Under Water Quality, no mention is made regarding protecting staff and public from 

discharged water. 

This is covered by the statement that “All water must be discharged according to State and Local 

Regulations”. Since state and local regulations vary, it is up to each institution to ensure their 

discharge policy conforms to the regulations in their area. These regulations should take into 

consideration the public exposure to the discharged water from the rehabilitation facility. Likewise 

all rehabilitation facilities should have Standard Operating Procedures in place to protect their staff 

from hazards which may be posed by the rehabilitation of marine mammals. 
THIS PAGE INTENTIONALLY LEFT BLANK 
 

 NOAA U.S. Fish and Wildlife Service 

National Marine Fisheries Service Fisheries and Habitat Conservation 

 Office of Protected Resources Marine Mammal Program 

FINAL 

POLICIES AND BEST PRACTICES

MARINE MAMMAL STRANDING RESPONSE, 

REHABILITATION, AND RELEASE

STANDARDS FOR RELEASE 

Prepared by 

Janet E. Whaley, D.V.M. February 2009 

NOAA National Marine Fisheries Service 

Marine Mammal Health and Stranding Response Program 

1315 East-Highway 

Silver Spring, Maryland 20910 

Rose Borkowski, D.V.M. 

Edited by 

Janet E. Whaley, D.V.M. 

Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Release February 2009 

i 

Standards for Release 

Table of Contents 

1. INTRODUCTION............................................................................................................. 1-1

1.1 Background......................................................................................................................1-1

1.2 Review of Key Legislation Pertinent to Marine Mammal Rehabilitation and Release to 

the Wild ...........................................................................................................................1-2

1.3 Structure of the Document...............................................................................................1-3

1.4 Funding ............................................................................................................................1-4

2. GENERAL PROCEDURES ............................................................................................... 2-1

2.1 Stranding Agreements, MMPA 109(h) Authority, and Permits for Stranding Response 

for ESA species ...............................................................................................................2-1

2.1.1 NMFS Policies....................................................................................................2-1

2.1.2 FWS Policies ......................................................................................................2-1

2.2 Parties Responsible for Release Determinations and Overview of Agency Approval ....2-1

2.3 Documentation for Rehabilitation and Release of Marine Mammals..............................2-4

2.3.1 NMFS .................................................................................................................2-4

2.3.2 FWS ....................................................................................................................2-6

2.4 Assessment Process for a Release Determination............................................................2-8

2.5 Emergency or Special Situations ...................................................................................2-15

3. GUIDELINES FOR RELEASE OF REHABILITATED CETACEANS .................................... 3-1

3.1 Introduction......................................................................................................................3-1

3.2 Overview of “Release Categories” for Cetaceans............................................................3-1

3.3 Historical Assessment of Cetaceans ................................................................................3-3

3.4 Developmental Assessment of Cetaceans........................................................................3-5

3.5 Behavioral Assessment of Cetaceans...............................................................................3-6

3.5.1 Breathing, Swimming and Diving ......................................................................3-7

3.5.2 Aberrant Behavior...............................................................................................3-7

3.5.3 Auditory and Visual Acuity................................................................................3-7

3.5.4 Prey Capture .......................................................................................................3-8

3.5.5 Predatory Avoidance...........................................................................................3-9

3.5.6 Social Factors......................................................................................................3-9

3.6 Medical and Rehabilitation Assessment of Cetaceans.....................................................3-9

3.7 Release Site Selection for Cetaceans .............................................................................3-11

3.8 Marking for Individual Identification of Cetaceans Prior to Release ...........................3-12

3.9 Post-Release Monitoring of Cetaceans ..........................................................................3-13

3.10 Decision Tree – Cetacean Release Categories...............................................................3-14

3.10.1 Releasable .........................................................................................................3-14

3.10.2 Conditionally Releasable ....................................................................................3-1

3.10.3 Non-Releasable...................................................................................................3-3

4. GUIDELINES FOR RELEASE OF REHABILITATED PINNIPEDS....................................... 4-1

4.1 Introduction......................................................................................................................4-1

4.2 Overview of Release Categories for Pinnipeds................................................................4-2

4.3 Historical Assessment of Pinnipeds.................................................................................4-4

4.4 Developmental Assessment of Pinnipeds ........................................................................4-6

4.5 Behavioral Assessment of Pinnipeds...............................................................................4-7
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Release February 2009 

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4.5.1 Breathing, Swimming, Diving, Locomotion on Land ........................................4-7

4.5.2 Aberrant Behavior...............................................................................................4-7

4.5.3 Auditory and Visual Function.............................................................................4-8

4.5.4 Prey Capture .......................................................................................................4-8

4.6 Medical Assessment of Pinnipeds ...................................................................................4-8

4.7 Release Site Selection for Pinnipeds..............................................................................4-10

4.8 Identification of Rehabilitated Pinnipeds Prior to Release ............................................4-12

4.9 Post-Release Monitoring of Pinnipeds...........................................................................4-12

5. GUIDELINES FOR RELEASE OF REHABILITATED MANATEES ..................................... 5-1

5.1 Introduction......................................................................................................................5-1

5.2 Overview of Release Categories for Manatees................................................................5-2

5.3 Historical Assessment of Manatees .................................................................................5-3

5.4 Developmental Assessment of Manatees.........................................................................5-4

5.5 Behavioral Assessment of Manatees ...............................................................................5-4

5.6 Medical Assessment of Manatees....................................................................................5-5

5.7 Decision Tree for Release Categories - Manatees ...........................................................5-6

5.7.1 RELEASABLE...................................................................................................5-6

5.7.2 CONDITIONALLY RELEASABLE .................................................................5-7

5.7.3 CONDITIONALLY NON-RELEASABLE .......................................................5-8

5.7.4 NON-RELEASEABLE ......................................................................................5-9

5.8 Pre-release Requirements for Manatees...........................................................................5-9

5.9 Release and Post-release Logistics for Manatees ..........................................................5-10

5.10 Manatee Rescue, Rehabilitation, and Rescue Program Reporting/Requesting 

Requirements.................................................................................................................5-11

6. GUIDELINES FOR RELEASE OF REHABILITATED SEA OTTERS ................................... 6-1

6.1 Introduction......................................................................................................................6-1

6.2 Developmental Assessment of Sea Otter Pups ................................................................6-1

6.3 Behavioral Assessment of Sea Otters ..............................................................................6-2

6.4 Medical Assessment of Sea Otters...................................................................................6-2

6.5 Release Categories for Sea Otters....................................................................................6-3

6.6 Identification of Sea Otters Prior to Release....................................................................6-3

6.7 Release Site Selection for Sea Otters...............................................................................6-4

6.8 Post-Release Monitoring of Sea Otters............................................................................6-4

7. POLICIES REGARDING RELEASE OF REHABILITATED POLAR BEARS ........................ 7-1

8. REFERENCES................................................................................................................. 8-1

Figures 

Figure 2.1 Documentation and Procedures Following Submission of the Written “Release 

Determination Recommendation.”.........................................................................................2-7

Figure 2.2 Steps and General Parameters for Animal Release Assessment ......................................2-16
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Release February 2009 

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Appendices 

Appendix A- Chronology of the Development of the Release Criteria 

Appendix B- Key Legislation: Marine Mammal Rescue, Rehabilitation, and Release to the Wild 

Appendix C- Required Reporting and Documentation

Appendix D- Diseases of Current Concern for Cetaceans 

Appendix E- Diseases of Current Concern for Pinnipeds 

Appendix F- Diseases and Issues of Current Concern for Manatees

Appendix G- Diseases of Current Concern for Sea Otters 

Appendix H- Contact Information for NMFS and FWS National and Regional Stranding Support 

Staff 

Appendix I- Cetacean and Pinniped-Species Specific Developmental Stages (Age-Length) and Social 

Dynamics 

Appendix J- “Recommended” Standard Checklists to Determine Release Category of All 

Rehabilitated Cetaceans and Pinnipeds (except walrus) 
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

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Executive Summary 

Rescue, rehabilitation, and release of wild marine mammals is allowed for authorized individuals 

under listed conditions by the Marine Mammal Protection Act (MMPA) [16 U.S.C. 1379 § 109(h)]. 

Section 402(a) of Title IV of the MMPA specifically mandates that “The Secretary shall... provide 

guidance for determining at what point a rehabilitated marine mammal is releasable to the wild” [16 

U.S.C. 1421 §402(a)]. This document fulfills the statutory mandate and is not intended to replace 

marine mammal laws or regulations. 

In accordance with the MMPA, these guidelines were developed by the National Oceanic and 

Atmospheric Administration’s (NOAA) National Marine Fisheries Service (NMFS) and the U.S. Fish 

and Wildlife Service (FWS) in consultation with marine mammal experts through review and public 

comment on the 1997 draft NOAA Technical Memorandum “Release of Stranded Marine Mammals 

to the Wild: Background, Preparation, and Release Criteria.” Comments from the public review 

process and other outstanding issues were compiled by NMFS and FWS. The agencies consulted 

with experts in three areas: cetaceans, pinnipeds and sea otters, and manatees. The experts reviewed 

and discussed the public comments and provided individual recommendations. This current 

document encompasses revisions and updates to the 1997 draft and is titled differently. 

These guidelines provide an evaluative process to help determine if a stranded wild marine mammal, 

following a course of treatment and rehabilitation, is suitable for release to the wild. These guidelines 

describe “Release Categories” for rehabilitated marine mammals of each taxonomic group (i.e., 

cetaceans, pinnipeds, manatees, sea otters and polar bears). After completing a thorough assessment 

as prescribed, the release candidates are to be assigned to a Release Category as follows: Releasable, 

Conditionally Releasable, Conditionally Non-releasable (Manatees only), and Non-releasable. 

This document establishes essential release criteria that trained experts should use to determine 

whether or not individual animals are healthy enough to release into the wild. The essential release 

criteria are assessed in the following categories: 

1) Historical Assessment 

2) Developmental and Life History Assessment 

3) Behavior Assessment and Clearance 

4) Medical Assessment and Clearance 

5) Release Logistics 

6) Post Release Monitoring 
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

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By using clearly defined Release Categories for rehabilitated marine mammals, NMFS and FWS can 

evaluate and support the professional discretion of the attending veterinarian and their assessment 

team (i.e., biologists, veterinarians, animal care supervisors, and other team members of the marine 

mammal stranding network). Based on these Release Categories, NMFS and FWS can consult 

experts on challenging cases in which the survival of the rehabilitated marine mammal or its potential 

to pose a health risk to wild marine mammals is in question. 

Refinement of requirements and guidelines for release of rehabilitated marine mammals to the wild is 

a dynamic process. Use of these standardized guidelines will also aid in the evaluation of 

rehabilitation procedures, successes, and failures, and will allow for on-going improvement of such 

protocols. These guidelines are based on the best available science and thus will be revised 

periodically. 
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

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1. Introduction 

1.1 Background 

Prior to the early 1990s, release decisions for marine mammal species under the jurisdiction of the 

National Marine Fisheries Service (NMFS) were made by individual rehabilitation facilities without 

much direction or input from NMFS. Decisions were inconsistent and invoked controversy, 

especially for cetacean cases. The Marine Mammal Commission and NMFS sponsored several 

workshops focusing on procedures and needs regarding marine mammal strandings, rehabilitation, 

and release (see Appendix A). Discussions at these workshops provided starting points for 

establishing objective release criteria. A stronger impetus to formalize these release guidelines came 

in 1992 when, as part of the Marine Mammal Health and Stranding Response Act, Congress 

mandated establishing objective guidelines for determining releasability of rehabilitated marine 

mammals. The Marine Mammal Protection Act (MMPA) was amended to include Title IV, Section 

402(a) which states that: “The Secretary [of Commerce] shall, in consultation with the Secretary of 

Interior, the Marine Mammal Commission, and individuals with knowledge and experience in 

marine science, marine mammal science, marine stranding network participants, develop objective 

criteria, after an opportunity for public review and comment, to provide guidance for determining 

at what point a rehabilitated marine mammal is releasable to the wild.” 

In accordance with the MMPA, these guidelines were developed by NMFS and the U.S. Fish and 

Wildlife Service (FWS) in consultation with marine mammal experts through review and public 

comment of the 1997 draft National Oceanic and Atmospheric Administration (NOAA) Technical 

Memorandum “Release of Stranded Marine Mammals to the Wild: Background, Preparation, and 

Release Criteria.” Comments from the public review process and other outstanding issues were 

compiled by NMFS and FWS. The agencies consulted with experts in three areas: cetaceans, 

pinnipeds and sea otters (Enhydra lutris), and manatees (Trichechus manatus). The experts reviewed 

and discussed the public comments and provided individual recommendations. This current 

document encompasses revisions and updates to the 1997 draft and is titled differently. 

The purposes of this document are as follows: 

1. To provide guidance for determining release of rehabilitated marine mammals to the wild 

including marine mammal species under the jurisdiction of the NMFS (Department of 

Commerce) and those under the jurisdiction of the FWS (Department of the Interior); 
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2. To state the NMFS and FWS legal requirements and provide recommendations for medical, 

behavioral, and developmental assessment of rehabilitated marine mammals prior to release; 

3. To identify the persons and agencies responsible for completing an assessment of a 

rehabilitated marine mammal for a release determination and to describe the communication 

requirements and process with NMFS or FWS; 

4. To state the NMFS and FWS requirements and recommendations for identification of 

releasable rehabilitated marine mammal, selection of a release site, and post-release 

monitoring; and 

5. This document does not include guidance for the following situations: 

a. Immediate release following health assessment and/or emergency triage typically 

associated with mass stranding events, out of habitat rescues, and disentanglement 

efforts. 

b. Release following relocation of healthy marine mammals. 

1.2 Review of Key Legislation Pertinent to Marine Mammal 

Rehabilitation and Release to the Wild 

Congress delegates the responsibility for implementing the MMPA to the Secretary of Commerce and 

the Secretary of the Interior. Cetaceans and pinnipeds, exclusive of walruses (Odobenus rosmarus), 

are the responsibility of NMFS (i.e., NMFS species). Walruses, polar bears (Ursus maritimus), 

manatees, and sea otters are the responsibility of FWS (i.e., FWS species). NMFS and FWS 

responsibilities for these species are regulated under 50 CFR (See Appendix B). 

Rehabilitation and release of wild marine mammals is authorized by key statements within the 

MMPA (16 U.S.C. 1379 §109(h)) entitled “Taking of Marine Mammals as Part of Official Duties.” 

This section allows for the humane taking of a marine mammal, by a Federal, State, or local 

government official or employee or a person designated under section 112(c) of the MMPA, for its 

protection or welfare and states that an animal so taken is to be returned to its natural habitat 

whenever feasible. Regulations that implement the MMPA for NMFS species (50 CFR 216.27(a)(1)) 

require that a marine mammal held for rehabilitation be released within six months unless “...the 

attending veterinarian determines that: (i) The marine mammal might adversely affect marine 

mammals in the wild; (ii) Release of the marine mammal to the wild will not likely be successful 

given the physical condition and behavior of the marine mammal; or (iii) More time is needed to 

determine whether the release of the marine mammal in the wild will likely be successful...” and 

(b)(1) “The attending veterinarian shall provide the Regional Director or Office Director with a 
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written report setting forth the basis of any determination.” Also, (a)(iii) “releasability must be reevaluated at intervals of no less that six months until 24 months from capture or import, at which time 

there will be a rebuttable presumption that release into the wild is not feasible.” 

For NMFS species, the MMPA section 112 (c) Stranding Agreements (formerly Letters of Agreement 

or LOAs) are formally established between the NMFS Regions and Stranding Network Participants. 

Understanding and following the MMPA and implementing regulations, policies, and guidelines, is 

the responsibility of all persons involved in marine mammal rescue, rehabilitation, and release. 

These guidelines are founded on and support the MMPA and related regulations. The laws and 

regulations outlined below are therefore fundamental to proper enactment of marine mammal 

rehabilitation and release. Appendix B contains the full titles and citations of these laws and 

regulations. 

1.3 Structure of the Document 

This document is organized as follows: General Procedures (Section 2); Guidelines for Release of 

Rehabilitated Cetaceans (Section 3); Guidelines for Release of Rehabilitated Pinnipeds (Section 4); 

Guidelines for Release of Rehabilitated Manatees (Section 5); Guidelines for Release of Rehabilitated 

Sea Otter (Section 6); Policies Regarding Release of Rehabilitated Polar Bears (Section 7); 

References (Section 8); Glossary of Terms (Section 9); and Appendices (Section 10). 

The approach developed in this document primarily involves a complete assessment of an animal’s 

health and behavior and release logistics. The assessment is completed by the attending veterinarian 

and their Assessment Team following this standardized guidance for determining the disposition of a 

marine mammal after treatment and rehabilitation. Section 2, “General Procedures,” summarizes the 

pertinent laws and regulations and outlines the release requirements and recommendations for all 

species of rehabilitated marine mammals. This section provides an overview of documentation 

required throughout rehabilitation and release. Parties responsible for release determinations are 

identified. General principles for developmental, behavioral, and medical assessments of 

rehabilitated marine mammals are described, as well as methods for post-release identification (i.e., 

marking and tagging), monitoring, and selection of appropriate release sites.

There are several critical variables among each taxonomic group, such as natural history, social 

organization, and species specific rehabilitation and release considerations. These variables are 

addressed in separate chapters (Sections 3-7) for cetaceans, pinnipeds, manatees, sea otters, and polar 
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

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bears. These chapters provide greater detail and rationale for the release guidelines for each marine 

mammal group. 

The reference section lists current literature on marine mammal biology, medicine, rehabilitation, and 

release. A glossary of terms is provided to define key terms initially noted in the text with italics. 

The appendices provide ready access to marine mammal laws and regulations and examples of 

required documentation for rehabilitated marine mammals. Additional appendices include examples 

correspondence letters between the Stranding Participant and NMFS, lists of Diseases of Concern, 

and related references for cetaceans, pinnipeds, manatees, and sea otters. 

1.4 Funding 

Funding of marine mammal rehabilitation is the responsibility of the rehabilitation facility. Specific 

resources, such as freezers for serum banking, histopathology services, equipment, and personnel for 

post-release monitoring may be provided through NMFS and FWS to support the biomonitoring 

program. Some costs associated with response and rehabilitation during a Marine Mammal Unusual 

Mortality Event (UME) may be reimbursed through the UME National Contingency Fund (in 

accordance with section 405 of the MMPA). For additional information regarding expense 

reimbursement, contact the appropriate NMFS or FWS coordinator. For NMFS species, the John H. 

Prescott Marine Mammal Rescue Assistance Grant Program is also available as a funding source for 

marine mammal stranding response and rehabilitation. More information on this program can be 

found on the following website: http://www.nmfs.noaa.gov/pr/health/prescott/. 
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

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2. General Procedures 

2.1 Stranding Agreements, MMPA 109(h) Authority, and Permits 

for Stranding Response for ESA species 

2.1.1 NMFS Policies 

NMFS may enter into a Stranding Agreement (formerly known as a Letter of Agreement or LOA) 

with a person or organization for stranding response and rehabilitation. The NMFS Stranding 

Agreement states that the Stranding Network Participant will obey laws, regulations, and guidelines 

governing marine mammal stranding response and rehabilitation. This includes requirements for 

communications with NMFS, humane care and husbandry and veterinary care of rehabilitated marine 

mammals, and documentation of each stranding response and rehabilitation activity. The Stranding 

Agreement does not authorize the taking of any marine mammal species listed as endangered or 

threatened under the Endangered Species Act of 1973 (ESA), as amended. However, authorization to 

take ESA-listed species by the Stranding Network is currently provided under MMPA/ESA Permit 

No. 932-1489-09, as amended, and requires authorization and direction from the NMFS Regional 

Stranding Coordinator in the event of a stranding involving a threatened or endangered marine 

mammal. 

2.1.2 FWS Policies 

Rescue, rehabilitation, and release of non ESA-listed marine mammal species under FWS 

responsibility is authorized with a Letter of Authorization (LOA) issued by the Division of 

Management Authority (DMA) in the FWS Headquarters Office in Arlington, VA. For ESA-listed 

species, an LOA holder is authorized under a permit issued by the DMA. The FWS Field Offices in 

the lower 48 states or the Marine Mammals Management Office in Alaska coordinate with LOA and 

permit holders for all rescue, rehabilitation, and release activities for species under their jurisdiction. 

2.2 Parties Responsible for Release Determinations and Overview 

of Agency Approval 

The attending veterinarian and their Assessment Team (i.e., veterinarians, lead animal care 

supervisor, and/or consulting biologist with knowledge of species behavior and life history) 

representing the Stranding Network Participant, Designee, or 109(h) Stranding Participant will assess 

the animal and make a written recommendation for release or non-release. For NMFS species, the 

recommendations are sent to the NMFS Regional Administrator. For FWS species, the 
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Standards for Release February 2009 

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recommendations are sent to the FWS Field Office and any recommendations for non-release 

are coordinated with the FWS Division of Management Authority. 

In general, for NMFS species that are deemed “Releasable,” a 15-day advance written notification is 

necessary. However, 50 CFR 216.27 (a)(2)(i)(A) allows for waiving this advance notification in 

writing by the Regional Administrator. Generally, these cases are anticipated (e.g., the typical annual 

cluster of cases where the etiology is known and diagnosis and treatment is routine) and can be 

appropriately planned. For such waivers, the Stranding Network Participant should submit a protocol 

for such cases, including location of release. These waivers will require pre-approval by the NMFS 

Regional Administrator on a schedule as prescribed in the Stranding Agreement. The release 

determination recommendation includes a signed statement from the attending veterinarian, in 

consultation with their Assessment Team, stating that the marine mammal is medically and 

behaviorally suitable for release in accordance with the release criteria (i.e., similar to a health 

certificate) and include a written release plan and timeline. NMFS may also require a concurrence 

signature from the “Authorized Representative” or Signatory of the Stranding Agreement. The 

Regional Administrator (i.e., NMFS staff) will review the recommendation and release plan and 

provide a signed written notification to the Stranding Network Participant indicating concurrence and 

authorization to release or direct an alternate disposition (letter of concurrence from the Regional 

Administrator) (50 CFR 216.27). For more challenging cases and potential “Conditionally 

Releasable” cases, plans for release should be submitted well in advance of the 15-day period to 

provide adequate time for evaluation. Also, it is highly recommended that dissenting opinions among 

members of the Assessment Team regarding an animal’s suitability for release and/or the release plan 

be communicated to NMFS well in advance of the required 15-day advance notice so that additional 

consultation can be arranged in adequate time for resolution and planning. 

By regulation (50 CFR 216.27 (a)(3), Appendix B), the NMFS Regional Administrator (or Office 

Director of Protected Resources) has the authority to modify requests for release of rehabilitated 

marine mammals. In accordance with 50 CFR 216.27 (a)(1), any marine mammal held for 

rehabilitation must be evaluated for releasability within six months of collection unless the “attending 

veterinarian determines that the marine mammal might adversely affect other marine mammals in the 

wild, release of the marine mammal to the wild will not likely be successful given the physical 

condition and behavior of the marine mammal, or more time is needed to determine whether the 

release of the marine mammal will likely be successful.” If more time is needed, then NMFS will 

require periodic reporting in writing from the attending veterinarian, including a description of the 
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Release February 2009 

2-3 

condition(s) of the animal that precludes release and a prognosis of release. NMFS may require that 

the marine mammal remain at the original rehabilitation facility or be transferred to another 

rehabilitation facility for an additional period of time, be placed in permanent captivity, or be 

euthanized. NMFS may also require a change of conditions of the release plan including the release 

site and post-release monitoring. An expanded release plan may be required including a justification 

and detailed description of the logistics, tagging, location, timing, crowd control, media coordination 

(if applicable) and post release monitoring. NMFS may require contingency plans should the release 

be unsuccessful including recapture of the animal following a specified time after release. 

Generally for animals deemed “Non-releasable” and with the concurrence from the NMFS Regional 

Administrator, the animal can be permanently placed in a public display or research facility or 

euthanized. If the animals is to be placed in permanent captivity, the receiving facility must be 

registered or hold a license from the U.S. Department of Agriculture’s Animal and Plant Health 

Inspection Service (APHIS) [7 U.S.C. 2131 et seq.] and comply with MMPA (16 U.S.C. 1374 

§104(c)(7)). These facilities (i.e., the rehabilitation facility or another authorized facility) are required 

to send a Letter of Intent to the Office of Protected Resources, Permits, Conservation and Education 

Division (NMFS PR1) to permanently retain or acquire the animal (information available at 

http://www.nmfs.noaa.gov/pr/permits/mmpa_permits.htm). This letter should include a signature of 

the “Responsible Party of Record”. As part of the decision making process, NMFS will consult with 

APHIS and may review the qualifications and experience of staff, transport protocols, and placement 

plans (i.e., integration based on appropriate composition of species, sex, and age and the intended 

proposed plan for public display or scientific research). Once approved, NMFS PR1 will respond 

with a Transfer Authorization Letter and include Marine Mammal Datasheets (MMDS), OMB Form 

0648-0084, to be returned to NMFS PR1 within 30 days of transfer. Upon receipt of the MMDS, 

NMFS PR1 will acknowledge the transfer in writing and return updated MMDS to the receiving 

facility. 

For FWS species, LOA and permit holders provide recommendations to the FWS Field Offices for 

decisions regarding releasability of rehabilitated marine mammals (see Appendix H for contact 

information). The FWS retains the authority to make the final determination on the disposition of 

these animals. If FWS determines that a marine mammal is non-releasable, the holding facility may 

request a permit for permanent placement in captivity as prescribed in section 104(c)(7) of the 

MMPA for non-depleted species, or section 104(c)(3) or section 104(c)(4) and section 10(a)(1)(A) of 

the ESA for depleted species. 
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Release February 2009 

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Manatee releases require a minimum 30-day advance notice (although exceptions may be made in the 

event of extenuating circumstances) and must also include a signed statement from the attending 

veterinarian that the animal is medically and behaviorally suitable for release in accordance with 

the release criteria (i.e., similar to a health certificate) and include a written release plan and 

timeline. Upon receipt, FWS will evaluate and determine the suitability of the release site and release 

conditions (see taxa specific sections for further guidance). 

For cases involving declared UMEs, the Working Group on Marine Mammal Unusual Mortality 

Events will be consulted to determine if event specific release standards should be implemented as 

stated in the 1996 NOAA Technical Memorandum – National Contingency Plan for Response to 

Unusual Marine Mammal Mortality Events. Priority will be given to protecting the health of wild 

populations over the disposition of an individual animal. Provisions may require monitoring a 

representative subset of released animals to determine survivability impact on the affected population 

or holding rehabilitated animals beyond the projected release time to determine long term health 

effects. 

2.3 Documentation for Rehabilitation and Release of Marine 

Mammals 

2.3.1 NMFS 

Pursuant to the Stranding Agreement between the Stranding Network Participant and appropriate 

NMFS Regional Office that allows a stranding organization to respond to and/or rehabilitate marine 

mammals, the Stranding Network Participant must provide documentation to NMFS regarding their 

activities that involve the taking and disposition of marine mammals as described below. The same 

holds true for actions under MMPA section 109(h). Figure 2.1 presents the documentation and 

procedures following submission of the written “release determination recommendation.” 

• Marine Mammal Stranding Report Level A Data, NOAA Form 89-864, OMB No. 0648-

0178 (Appendix C). 

This report is mandatory for all stranding events and includes basic information regarding the 

site and nature of the stranding event, a statement that the animal was found alive or a 

description of the condition of its carcass, morphologic information, photo or video 

documentation, initial disposition of any live animal, tag data, and information on disposal, 

disposition, and necropsy of dead animals. This report must be sent to the appropriate NMFS 

Regional Office within the time stated in the Stranding Agreement. 
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Release February 2009 

2-5 

• Marine Mammal Rehabilitation Disposition Report, NOAA Form 89-878, OMB No. 

0648-0178 (Appendix C) 

This report is mandatory for all rehabilitation cases (i.e., long-term and short-term temporary 

holding) and includes a brief history of the stranding and related findings of an individual 

marine mammal. It also includes the disposition of samples taken from the animal and 

disposition of the animal including release site and tagging information. This report includes 

verification and date that a pre-release health screen was done on the animal. This document 

must be sent to the appropriate NMFS Regional Office no later than 30 days following the 

final disposition (e.g. released or non-released) of the marine mammal or as prescribed in the 

Stranding Agreement. NMFS compiles these data annually to monitor success of 

rehabilitation and identify where changes and enhancements should be made. 

• Release Determination Recommendation 50 CFR 216.27 (a)(2) (Appendix B) 

This regulation states that the custodian of a rehabilitated marine mammal must provide the 

appropriate NMFS Regional Office with written notification at least 15 days prior to the 

release of any marine mammal to the wild, including a release plan. The pre-notification 

requirement may be waived in writing for certain circumstances (e.g., the typical annual 

cluster of cases where the etiology is known and diagnosis and treatment is routine) by the 

NMFS Regional Administrator in accordance with specific requirements as stated in the 

Stranding Agreement. The required notification (release determination recommendation) 

should provide information sufficient for determining the appropriateness of the release plan, 

including a description of the marine mammal (i.e., physical condition and estimated age), the 

date and location of release, and the method and duration of transport prior to release (50 

CFR 216.27(a)(2)(ii)). The release recommendation should include a signed report or 

statement from the attending veterinarian that the marine mammal is medically and 

behaviorally suitable for release in accordance with NMFS release criteria (i.e., similar to a 

health certificate under the Animal Welfare Act). NMFS may also require a concurrence 

signature from the “Authorized Representative” or Signatory of the Stranding Agreement. In 

the case of more challenging releases such as animals considered Conditionally Releasable,” 

requests for release should be submitted well in advance of the 15-day period to provide 

adequate time for review and planning. NMFS reserves the right to request additional 

information and impose additional requirements in any release plan to improve the likelihood 

of success or to protect wild populations (50 CFR 216.27 (a)(3)). NMFS also can order other 

disposition as authorized upon receipt of the report (release determination recommendation) 
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Release February 2009 

2-6 

(50 CFR 216.27 (b)(2). For guidance, see Appendix J for a Recommended Standard 

Checklist for Release Determination. 

• Notification of Nonrelease/Transfer of Custody

For animals deemed “Non-releasable,” and with the concurrence from the NMFS Regional 

Administrator, the animal can be permanently placed in a public display or research facility 

or be euthanized. If the animal is to be placed in permanent captivity, the receiving facility 

must be registered or hold a license from APHIS [7 U.S.C. 2131 et seq.] and comply with 

MMPA (16 U.S.C. 1374 §104(c)(7)). Facilities wishing to obtain non-releasable animals 

should send a Letter of Intent to NMFS PR1 to permanently retain (i.e., if affiliated with the 

rehabilitation facility) or acquire the animal. This letter should include a signature of the 

“Responsible Party of Record”. As part of the decision making process NMFS will consult 

with APHIS and may review the, qualifications and experience of staff, transport, and 

placement plans (i.e., integration based on appropriate composition of species, sex, and age 

and the intended proposed plan for public display or scientific research). Once approved, 

NMFS PR1 will respond with a Transfer Authorization Letter and include MMDS, OMB 

Form 0648-0084, to be returned to NMFS PR1 within 30 days of transfer. Upon receipt of 

the MMDS, NMFS PR1 will acknowledge the transfer in writing and return updated MMDS 

to the receiving facility. 

2.3.2 FWS 

Requirements for the rehabilitation and release of marine mammals under FWS jurisdiction are 

specified under individual permits or LOAs. These requirements are specific to the species, the 

organization, and the activity being conducted. The required documentation for manatee rescue, 

rehabilitation, and release activities is provided in Appendix C. 
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Release February 2009 

2-7 

< 6 Month

Disposition Report

"Release Determination Recommendation"

Signed and Dated by Attending Veterinarian and Authorized 

Representative

15-30 Day Advance Notice 

Pre-approved Waiver 

CONDITIONAL 

RELEASE RELEASE NONRELEASABLE

Letter of Concurrence from Agency (RA)

Letter of Concurrence 

from Agency (RA)

Release Logistics and Biomonitoring Plan 

Contingency Plan 

Response to restranding 

(recapture plan)

Rehabilitation and Re-release

Euthanasia

RELEASE or Alternate Dispositon

Submit Rehabilitation Disposition Report to NMFS 

Region (30d) 

Agency Review

Letter of Intent from permanent 

care facility to NMFS PR1

APHIS License Concurrence

TRANSFER OF CUSTODY

Submit Rehabilitation Disposition Report to 

NMFS Region (30d)

Submit Verification of Transfer and Marine 

Mammal Data Sheet to NMFS PR1 (30d) 30 d

Transfer Authorization Letter 

from Agency (NMFS PR1) ASAP

+

C

ONSULT

+/-

C

ONSULT

+

C

ONSULT

Figure 2.1 Documentation and Procedures Following Submission of the Written “Release 

Determination Recommendation.”
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Release February 2009 

2-8 

2.4 Assessment Process for a Release Determination 

These guidelines provide an evaluative process to determine if a stranded wild marine mammal, 

following a course of treatment and rehabilitation, is suitable for release to the wild. The basic format 

for these guidelines provides assignments for each taxonomic group (e.g., cetaceans, pinnipeds, 

manatees, sea otters, walrus, and polar bears) of rehabilitated marine mammals into “Release 

Categories.” Release potential is characterized and categorized based on a thorough assessment of 

the health, behavior, and ecological status of the animal, as well as the release plan. It is critical that 

detailed historical, medical, and husbandry records are maintained and reviewed. Following a 

complete evaluation, the attending veterinarian and Assessment Team should categorize the animal 

into one of the following Release Categories: Releasable, Conditionally Releasable, Conditionally 

Non-releasable (for manatees only), and Non-releasable. “Conditionally Non-releasable” is only a 

category for manatees because the FWS has had success releasing manatees that have been in 

captivity in excess of 20 years. NMFS species are deemed “Non-releasable” if they have been in 

captivity for over two years (see 50 CFR 216.27(a)(1)(iii)) and therefore a “Conditionally Nonreleasable” category is not necessary. Based on the findings from the Assessment Team, the 

attending veterinarian provides a recommendation on releasability to NMFS or FWS. The Agencies 

will review and consider this information as a part of the release determination review process. 

In most release cases, NMFS requires the release of marine mammals within six months of admission 

to rehabilitation (50 CFR 216.27(a)). This assessment can be done at more frequent intervals or 

earlier in the process of rehabilitation such as for obvious nonrelease cases (e.g., neonatal cetaceans, 

blind or deaf animals, etc). Rather than staying in a rehabilitation situation for up to six months, it 

may be in the best interest of the animal to immediately assess, determine releasability, and transfer to 

a more suitable permanent care facility. This is particularly important for all marine mammals that 

need socialization or expert care. 

The Assessment should include the following steps and general parameters (see Figure 2.2 on 

page 2-16): 

1. Historical Assessment. The Assessment Team should complete a historical evaluation that 

includes information gathered from the time of stranding through the duration of 

rehabilitation. Such information can impact the management of the case and determination of 

release. Circumstances such as an ongoing epidemic among other wild marine mammals, 

presence of environmental events such as a harmful algal bloom or hazardous waste spill, 
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Release February 2009 

2-9 

acoustic insult; and special weather conditions (e.g., El Niño, hurricane, extreme cold, 

extreme heat, changes in oceanographic parameters, etc.) should be documented. It should be 

noted if the animal: had previously stranded and been released; was part of an official UME; 

had been exposed to other wild or domestic animals just prior to and/or during rehabilitation; 

or had attacked and/or bitten (including mouthing of unprotected skin) a human while being 

handled. This assessment should also include if the animal is evidence and part of a human 

interaction or criminal investigation. Such information can help guide the diagnostic and 

treatment strategy during rehabilitation and may impact the plan for post-release monitoring. 

It should be noted that strict measures are to be in place to prevent any disease transmission 

from other wild and domestic animals and humans during the rehabilitation process. Other 

considerations that should be taken into account include whether the animal was transferred 

from another facility (i.e., short-term triage/holding facility or rehabilitation facility) and the 

quality of care and treatment of each rehabilitation facility.

2. Developmental and Life History Assessment. In order to be deemed “Releasable,” all 

rehabilitated marine mammals should have achieved a developmental stage wherein they are 

nutritionally independent. Nursing nutritionally dependent animals should not be 

released in the absence of their mothers. The ability of a young marine mammal to hunt 

and feed itself independently of its mother is critical to successful integration into the wild. 

Also of great importance is achievement of a robust body condition such that the animal has 

adequate reserves for survival. Other developmental issues, such as reproductive status and 

advanced age, seldom stand alone as determinants of release candidacy but are evaluated in 

conjunction with the overall health assessment. The Assessment Team should seriously 

consider information concerning the natural life history for the species. Therefore, it is 

important that the makeup of the team include someone with expertise or working 

understanding of the species behavior and life history. Important questions to be addressed 

include: 1.) does the species depend on a social unit for survival or does it exist solitarily in 

the wild?; 2.) has the animal developed the skills necessary to find and capture food in the 

wild?; 3.) has the animal developed the social skills required to successfully integrate into 

wild societies?; 4.) is there knowledge of their home range or migratory routes?; and 5.) does 

the animal have skills in predator recognition and avoidance? In other words, how important 

is it to the survival of the animal to be released with or near other cohorts? The Assessment 

Team can work with NMFS to consult with outside experts to evaluate the animal and 
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Release February 2009 

2-10 

address these questions. Greater details regarding developmental assessment are included in 

the appropriate section for each taxonomic group. 

3. Behavioral and Ecological Assessment and Clearance. In order to be deemed 

"Releasable," a marine mammal should meet basic behavioral criteria and some of which are 

specific for taxa. Across taxonomic groups, behavioral requirements for release include 

demonstration of normal breathing, swimming, and diving with absence of aberrant (i.e., 

abnormal) behavior, auditory, and/or visual dysfunction that may significantly compromise 

survival in the wild and/or suggest diseases of concern. The rehabilitated animal should also 

demonstrate the ability to recognize, capture, and consume live prey prior to its release when 

access to live natural prey is feasible, or, in the case of manatees, the ability to identify and 

feed on appropriate forage types. Because abnormal behavior may reflect illness or injury, 

this should be done in concert with the attending veterinarian and the medical assessment. 

The behavioral clearance should be part of the overall recommendation for release that is 

passed on to NMFS or FWS. Outstanding concerns regarding the behavioral suitability of the 

marine mammal for release are to be discussed with NMFS or FWS. Additional information 

is included in the behavioral assessment section for each taxonomic group. 

Also included in this thought process, is the concept of ecological status. This concept 

attempts to integrate the medical and behavioral evaluations into an extrapolation of how the 

animal would likely do in the wild when exposed to typical ecological pressures (personal 

comm. Wells 2005). It goes beyond the assessment of the current condition of the animal in 

an artificial environment at the rehabilitation facility relative to a limited set of immediately 

observable or measurable parameters. It places the animal in its current rehabilitated 

condition in the context of life in the wild. This process recognizes the importance of a team 

approach, involving complementary expertise, to evaluate the probability that a rehabilitated 

animal will survive and thrive back in the wild. It would be useful to include in the 

deliberations a behavioral ecologist with knowledge of the species specific (or closely related 

species) solutions to ecological challenges in the wild. The behavioral ecologist would be 

familiar with the species habitat, including oceanographic parameters, ranging patterns, life 

history, feeding ecology, potential predators, social structure, and anthropogenic threats likely 

to be faced by the animal once it is released. 
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Release February 2009 

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4. Medical Assessment and Clearance. Although this document focuses on the evaluation and 

preparation of rehabilitated marine mammals for release, the medical assessment spans the 

entire time the animal is in rehabilitation and is critical to understanding the animal’s health 

prior to release. The medical assessment includes information related to any health trend and 

diagnostic testing, treatment, and response to treatment. The attending veterinarian should 

perform a hands-on physical examination upon admission and prior to the release 

determination. The attending veterinarian should review the animal’s complete history 

including all stranding information, diagnostic test results (i.e., required by NMFS or FWS), 

and medical and husbandry records. The goal of required testing requested by NMFS or 

FWS is to safeguard the health of wild marine mammal populations and this is achieved by 

testing for diseases (reportable diseases) that pose a significant morbidity or mortality risk to 

wild populations. 

Other reportable diseases include those that are of zoonotic or public health and safety 

concern and the agencies will require immediate notification to assure proper protocols are 

put into place. The agencies may request testing for other emerging diseases as part of a 

surveillance program to identify potential epidemics of concern or to determine health trends. 

Additional testing will be required if the animal was part of an official UME. Specific testing 

requirements (i.e., pre-release health screen) will come from the NMFS Marine Mammal 

Health and Stranding Response Program (MMHSRP) through the National Stranding 

Coordinator and follows the term and responsibilities stated in the NMFS Stranding 

Agreement. For FWS species, contact the appropriate Field Office for guidance (see 

Appendix H for contact information). 

Throughout the rehabilitation period, the frequency of physical exams and decisions for 

performance of additional diagnostic testing are determined by the attending veterinarian. 

The animal should be closely monitored for disease throughout rehabilitation. Regardless of 

the precise cause of the animal’s stranding, the stranding event itself and the animal’s abrupt 

transition to a captive environment can cause significant stress, which may increase its 

susceptibility to disease (St. Aubin and Dierauf 2001). The rehabilitation facility may also 

harbor pathogens not encountered in the wild or new antibiotic resistant strains (Measures 

2004, Moore et al. 2007, Stoddard et al. in press). Should the animal become infected with 

such a pathogen during rehabilitation, it could become ill or become a carrier of that pathogen 

and may pose a threat to a naïve wild population or even public health if it is released. 
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

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Introduction of pathogens from rehabilitated animals to free-ranging wild animals is a 

significant concern for diseases with serious epizootic or zoonotic potential (Gilmartin et al.

1993, Griffith et al. 1993, Spalding and Forrester 1993). Pathogens, particularly viruses, 

bacteria, and some protozoans, can quickly replicate in their hosts and are susceptible to 

selective forces that can drive microbial adaptation and evolution leading to changes in 

transmission rates, virulence, and pathogenicity via genetic modification (Ewald 1980, 1983, 

1994; Su et al. 2003). Thus, infectious agents may become more pathogenic as they pass 

through new individuals and naïve species. 

The attending veterinarian is urged to utilize the full spectrum of diagnostic modalities 

available for health assessment of the animal. In addition to basic blood work, serology, 

microbial culture, cytology, urinalysis, and fecal exam, advanced techniques for pathogen 

detection such as Polymerase Chain Reaction (PCR), microarrays, and toxicology 

assessments are also available. A number of imaging techniques including radiology, 

bronchoscopy, and laparoscopy may also be utilized. The marine mammal literature has 

expanded to include numerous references on the performance and interpretation of diagnostic 

tests (see references and Appendices D, E, F, and G for partial list). 

Except as otherwise noted, acquisition of blood for a complete blood count (CBC) and 

chemistry profile plus serum banking may be required by NMFS and FWS upon admission of 

a marine mammal to a rehabilitation facility. Such blood work should to be repeated by the 

original laboratory, to avoid problems with inter-laboratory variability, prior to release of the 

marine mammal. Microbial culture and isolation (i.e., aerobic and anaerobic bacterial, viral, 

fungal) should be a part of the medical evaluation and done upon admission and before exit 

from rehabilitation centers. Such paired tests help determine the types of pathogens that a 

marine mammal may have acquired in the wild and those that may have been acquired during 

its rehabilitation. Because the number of pinnipeds entering a rehabilitation facility annually 

may be quite high and presenting with similar diagnosis, particularly in El Niño years, NMFS 

may waive additional clinical evaluation as mentioned above for each pinniped but instead 

require that a percentage of these animals entering a facility have a thorough clinical workup. This will be dependent on several factors, such as the stranding location, time of year, the 

clinical diagnosis upon admission, and disease status of the wild population (e.g., ongoing 

outbreaks, UMEs, etc). For walrus and polar bears, testing requirements will be on a case-by-
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Release February 2009 

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case basis. The NMFS or FWS stranding coordinator can provide guidance on this and other 

recommendations mentioned above. 

The attending veterinarian interprets the results of blood work and additional diagnostic tests 

in light of physical exam findings, the animal’s age, reproductive status, molt status, 

behavior, and other relevant or historical factors. Circumstances surrounding the stranding, 

recent environmental events, known health issues of resident wild marine mammals, and 

exposure to other animals are examples of historical factors that may provide information 

regarding the health status of the stranded marine mammal. The attending veterinarian should 

also consider if the animal was held in close proximity to other animals (e.g., penmates) 

undergoing rehabilitation and the disease history of those animals (e.g., within facility 

transmission). A number of references provide data useful for the interpretation of marine 

mammal diagnostic tests. Appendices E, F, G and H provide information on diseases of 

concern for cetaceans, pinnipeds, manatees and sea otters. 

5. Release Considerations. 

a. Required Identification Prior to Release. Marine mammals must be marked prior 

to release for individual identification in the wild (see 50 CFR Sec. 216.27(a)(5) for 

species under NMFS jurisdiction). Examples of identification systems include 

flipper roto tags, flipper All-Flex tags, flipper Temple tags, passive integrated 

transponder tags (PIT tags), radio tags, satellite tags, and freeze branding (Geraci and 

Lounsbury 2005). Invasive tag application procedures should be done under the 

direct supervision of the attending veterinarian and will need prior approval from 

NMFS and FWS and may require a monitoring period following the procedure. 

Proper photo identification for some species should also be considered part of the 

protocol. Standard identification protocols exist for various groups of marine 

mammals that detail the methods and procedures for marking for future identification 

in the wild, and are included in the appropriate section for each taxonomic group. 

Contact the Agency stranding coordinator for additional information. 

As described, roto tags or flipper tags (basic tags) for cetaceans and pinnipeds 

(except walrus) are to be obtained from or coordinated through the NMFS Regional 

Stranding Coordinator. For FWS species, tags for walrus are to be obtained from the 

USGS and tags for polar bears are obtained from FWS. Tags for manatees are to be 
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Release February 2009 

2-14 

obtained from FWS or the appropriate State Agency. Tags for sea otters are obtained 

by each individual LOA or permit holder. 

Depending on the species, if the animal restrands or the tag is found, this information 

should be reported to the appropriate NMFS or FWS and/or USGS Stranding 

Coordinator. The NMFS National Marine Mammal Stranding Database centrally 

archives tag data for NMFS species. The FWS and/or USGS track these data for 

walruses, sea otters, and polar bears. For manatees, the State agencies maintain the 

tag data. 

b. Release Site Requirements and Recommendations. Rehabilitated marine 

mammals are to be released to the wild under circumstances that reflect the natural 

history of their species and maximize the likelihood for their survival. This will vary 

with age and sex of the individual. Timing should be set to minimize additional 

energetic and social demands, and maximize foraging success and ease of social 

acceptance with conspecifics. For NMFS species, information regarding the date, 

location, and logistics of the release and any other information requested are included 

in the required 15-day advance notification of the Agency prior to release as cited in 

50 CFR 216.27 (a)(2). Key factors in determining a release site include specific 

habitat, geographic and environmental factors such as weather and oceanographic 

states, past successful releases, public use, potential for predators, and availability of 

prey as well as transport time. Maintenance of stock fidelity, proximity of 

conspecifics, timing in relation to breeding seasons and migration activities are also 

crucial considerations. As the natural history of each species provides the framework 

for planning a release, greater details for each taxonomic group are provided in the 

appropriate section of this document. 

6. Post-Release Monitoring. Post-release monitoring is a key method by which the efficacy of 

rehabilitation efforts can be assessed and revised. Such monitoring may also provide an 

opportunity to recover individuals that are unable to readjust to the wild. Simple post-release 

monitoring plans include such methods as visually tracking tagged or marked animals by 

land, air, or sea. More costly radio-telemetry and satellite tracking are highly desirable 

methods of post-release monitoring as they provide detailed information of the movement 

and behavior of released marine mammals. Post-release monitoring is recommended for all 
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Release February 2009 

2-15 

rehabilitated marine mammals and is required for some taxonomic groups, such as cetaceans 

and manatees, depending on release category. The intensity of post-release monitoring 

efforts is determined by such factors as the age and species of the marine mammal, its status 

as threatened or endangered, and concerns regarding its health or developmental issues that 

may impact its ability to readjust to the wild. Advanced post-release monitoring techniques 

may be required for "Conditionally Releasable" animals when significant concerns regarding 

their chances of survival exist. All post-release monitoring plans for rehabilitated marine 

mammals are to be approved in writing by, and coordinated with, NMFS or FWS. NMFS 

may require the submission of follow-up monitoring summaries at specified intervals postrelease (e.g., 90 day intervals), until such time as contact with the animal has ended. The 

final update should include tracking data and an evaluation of the success of the rehabilitation 

and release along with recommendations for future cases. NMFS may use these data in order 

to make future revisions to marine mammal rehabilitation and release guidelines. In order to 

compare individual cases, standardization of data collection protocols for monitoring released 

animals is highly recommended and may be required by NMFS. Formal study of monitoring 

data and its dissemination to the stranding network will aid in the assessment of marine 

mammal rehabilitation and release programs. 

2.5 Emergency or Special Situations 

NMFS and FWS are responsible for monitoring and protecting the health of wild marine mammal 

populations. To fulfill this responsibility, and as stated in the NMFS Stranding Agreements, these 

agencies may require or recommend increased documentation, testing, and/or post-release monitoring 

of rehabilitated marine mammals when a stranding event appears to be related to wide spread 

environmental events such as algal blooms, hazardous waste spills, outbreaks of disease, UMEs, etc. 

An increased incidence of illness or injury to marine mammals may prompt NMFS or FWS to require 

specific diagnostic testing as part of a surveillance program and additional communication regarding 

case outcomes. NMFS and FWS personnel are to provide Stranding Network Participants and 

rehabilitation facilities with this information and may be able to provide additional funding and other 

support regarding such circumstances. For example, NMFS holds contracts with specific diagnostic 

labs that can provide services for rehabilitation facilities free of charge. 
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Release February 2009 

2-16 

Stranding

History

Development

&

Life History

Behavior

&

Ecological

Medical

Release

Logistics

Post Release

Monitoring

(if required)

Requirements

for Emergency

or Special

Situations

(if required)

YES

Concerns

Can be resolved

Conditional

Releasable

Nonreleasable

< 6 month

intervals

Nonreleasable

Nonreleasable

Nonreleasable

Nonreleasable

Nonreleasable

Nonreleasable

YES

Concerns

Cannot be resolved

YES

Concerns

Cannot be resolved

YES

Concerns

Cannot be resolved

YES

Concerns

Cannot be resolved

YES

Concerns

Cannot be resolved

YES

Concerns

Cannot be resolved

YES

Concerns

Cannot be resolved

YES

Concerns

Can be resolved

YES

Concerns

Can be resolved

YES

Concerns

Can be resolved

YES

Concerns

Can be resolved

YES

Concerns

Can be resolved

YES

Concerns

Can be resolved

Conditional

Conditional

Conditional

Conditional

Conditional

Conditional

NO Concerns

NO Concerns

NO Concerns

NO Concerns

NO Concerns

NO Concerns

NO Concerns

Releasable

Releasable

Releasable

Releasable

Releasable

Releasable

ASSESSMENT

ASSESSMENT

TEAM

 Figure 2.2 Steps and General Parameters for Animal Release Assessment 
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Release February 2009 

3-1 

3. Guidelines for Release of Rehabilitated Cetaceans 

3.1 Introduction 

Few species of cetaceans (i.e., primarily bottlenose dolphins, rough-toothed dolphins, grampus 

dolphins, and harbor porpoise) are rehabilitated in the United States each year. Although the natural 

history of cetaceans differs among the various species, the general release criteria set forth in this 

document are applicable to all cetaceans in the United States. Prior to the release of any cetacean, 

NMFS requires that a thorough evaluation of the historical, developmental, behavioral, and medical 

records and status be completed by the Assessment Team (i.e., Stranding Network Participant, 

attending veterinarian, animal care supervisor, and biologist with knowledge of species behavior, 

ecology, and life history). For all cetacean cases, a release determination recommendation must be 

sent to the NMFS Regional Administrator at least 15 days (typically 30 days) in advance of a 

proposed release date. Waivers for advanced notice are not generally considered in cetacean cases. 

The release determination recommendation must include a signed statement from the attending 

veterinarian in consultation with their Assessment Team that the animal is medically and 

behaviorally suitable for release in accordance with the release criteria and include a written 

release plan and timeline. The request should also include a statement(s) from an expert biologist(s) 

with knowledge of the species or similar species that is being considered for release and should state 

that the animal meets behavior and ecological criteria for release in accordance with the release 

criteria. NMFS may recommend or require additional testing beyond these guidelines for reportable 

diseases in light of new findings regarding various disease and health issues. A release plan will 

require a justification statement and detailed description of the logistics for transporting, tagging, 

location, timing, crowd control, media coordination (if applicable), post-release monitoring, and 

recovery should the animal fail to thrive. NMFS may require a recapture contingency plan if the 

animal appears to be in distress or poses a risk following a specified time after release. NMFS may 

consult with individual experts for further guidance. NMFS reserves the right to impose additional 

requirements in the release plan as stated in 50 CFR 216.27 (a)(3). 

3.2 Overview of “Release Categories” for Cetaceans 

Cetaceans evaluated at rehabilitation facilities can be grouped into one of three “Release Categories” 

based on historical, developmental, behavioral, ecological, and medical criteria set forth in a 

standardized checklist. It is recommended that the standardized checklist (see Appendix J) be used 

to assess and document the release candidacy of rehabilitated cetaceans. The checklist includes a 
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health statement (i.e., health certificate) to be signed by the attending veterinarian and authorized 

representative, which verifies that a cetacean meets appropriate standards for release. This checklist 

could be used to determine and document releasability (i.e., as part of the required documentation 

sent to NMFS – refer to Figure 2.1) and as a final check just prior to release. 

The case should fit into one of three “RELEASE CATEGORIES:”

1. “RELEASABLE”: This category indicates that there are no significant concerns related to 

the likelihood of survival in the wild and/or risk of introducing disease into the wild 

population. Also, the animal meets basic historical, developmental, behavioral, ecological, 

and medical release criteria. The release plan has been approved in writing by NMFS 

Regional Administrator via a letter of concurrence to the applicant. 

2. “CONDITIONALLY RELEASABLE”: This category indicates that there are concerns 

about the historical, developmental, behavioral, ecological, and/or medical status of the 

animal, raising a question of survival or health risk to wild marine mammals. A cetacean 

may be deemed conditionally releasable if requirements for release cannot be currently met 

but may be met in the future without compromising the health and welfare of the individual 

animal. In such cases, more time may be needed to determine the feasibility of release (see 

50 CFR 216.27(a)(1)(iii)). 

All “Conditionally Releasable” cetaceans must be discussed with NMFS. For some cases, 

NMFS may consult with individual experts to seek additional advice. The experts may 

include scientists and veterinarians with expertise in cetacean biology and medicine (i.e., 

particularly experts with species-specific knowledge). These discussions may reveal that 

additional medical testing, rehabilitative therapy, and strategies for post-release monitoring 

may be required to release a "Conditionally Releasable" cetacean. 

3. “NON-RELEASABLE”: This category indicates that there are significant historical, 

developmental, behavioral, ecological, and/or medical concerns regarding its release to the 

wild. It has a documented condition demonstrating little chance for survival in the wild 

and/or a diagnosed health risk to wild marine mammals. This category also includes animals 

that have been in rehabilitation greater than two years (see 50 CFR 216.27(a)(1)(iii)). 

Additionally, a cetacean may be deemed “Non-Releasable” if an appropriate release site or 

post-release monitoring plan cannot be arranged. 

For animals deemed “Non-releasable,” and with the concurrence from the NMFS Regional 

Administrator, the animal can be permanently placed in a public display or research facility or 
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euthanized. If the animal is to be placed in permanent captivity, the receiving facility must be 

registered or hold a license from APHIS [7 U.S.C. 2131 et seq.] and comply with MMPA (16 U.S.C. 

1374 §104(c)(7)). Facilities wishing to obtain non-releasable animals should send a Letter of Intent to 

NMFS PR1 to permanently retain (i.e., if affiliated with the rehabilitation facility) or acquire the 

animal. This letter should include a signature of the Responsible Party of Record. As part of the 

decision making process NMFS will consult with APHIS and may review the qualifications and 

experience of staff, transport, and placement plans (i.e., integration based on appropriate composition 

of species, sex, and age and the intended proposed plan for public display or scientific research). 

Once approved, NMFS PR1 will respond with a Transfer Authorization Letter and include MMDS 

and OMB Form 0648-0084, to be returned to NMFS PR1 within 30 days of transfer. Upon receipt of 

the MMDS, NMFS PR1 will acknowledge the transfer in writing and return updated MMDS to the 

receiving facility. 

3.3 Historical Assessment of Cetaceans 

Historical stranding information may guide the management of rehabilitation and the plan for postrelease monitoring. Important historical information should include: 

1. A record of previous stranding – Stranded cetaceans that have previously stranded and been 

released, and subsequently strand again, are deemed “Conditionally Releasable” for further 

release attempts pending consultation with NMFS. Such animals should be reassessed and as 

they may have underlying health issues requiring additional evaluation, diagnostic testing, 

and advanced post-release monitoring. Alternatively, such cetaceans may be assessed as 

“Non-Releasable” and be transferred to permanent captivity or euthanized. 

2. A mother-calf pair – A stranding of a mother/calf pair may be the result of illness or injury 

to either the mother, calf, or both. If the calf dies or is euthanized, the mother could be 

considered for release following a thorough and appropriate assessment. If the mother dies or 

is euthanized, a dependent calf is likely non-releasable because it cannot forage on its own 

and should be placed in permanent captivity or euthanized. 

3. An association with an ongoing epidemic among other wild marine animals or a UME –

If the stranding of a cetacean occurs close to (i.e., temporally and geographically) an ongoing 

epidemic of wild marine animals or to a UME, fish kill, harmful algal bloom, hazardous 

waste spill, or other such environmental event, the cetacean is deemed “Conditionally 

Releasable” and consultation with NMFS is required. NMFS may request additional testing, 

documentation, and/or post-release monitoring of such cetaceans. 
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4. Stranding location and active/home range – Stranded cetaceans may be deemed 

“Conditionally Releasable” if they stranded in areas where there is an increase in human 

activity (e.g., active fishery, increased recreational use, military activity, shipping activity, 

etc.) or hazardous environmental conditions (e.g., harmful algal bloom or hazardous waste 

spill, and/or special weather conditions like El Niño, hurricane, extreme cold, extreme heat, 

etc). The geographical distance between the stranding location and the rehabilitation facility 

is important to acknowledge, as there could be important differences in the microflora in the 

facility’s water system. Information on areas of human activity and environmental hazards is 

also vital for determining an appropriate release site. 

5. The animal has been exposed to (or injured by) other wild or domestic animals –

Stranded cetaceans with a history of exposure to terrestrial wild (e.g., raccoons, coyotes, etc.) 

or domestic animals (e.g., cats, dogs, etc.) are deemed “Conditionally Releasable” and must 

be discussed with NMFS. There is a potential for zoonotic pathogens to be transmitted 

between wild or domestic animals to marine mammals but signs of clinical disease are 

undetectable. Additional testing may be required to better assess the health status and 

decrease the potential for transmitting diseases of concern to wild marine mammal 

populations following release. Consultation with NMFS is required for cetaceans that have a 

history of exposure to terrestrial animals. 

6. The animal was transferred from another holding, triage or rehabilitation facility – The 

opportunity for exposure to pathogens can occur at different stages of response and 

rehabilitation. Therefore, it is important to obtain medical records and document the quality 

of care and treatment at each stage of this process. 

7. The animal was evidence or part of a human interaction or criminal investigation – This 

includes an investigation by NOAA Office of Law Enforcement, the U.S. Department of 

Justice, or other Federal, state or local authorities. 

8. The animal was part of a mass stranding (stranding involving more than one cetacean if 

not a cow-calf pair) – Mass strandings are typically influenced by behavior, with the 

majority of stranded animals being healthy but in need of assistance to return to the ocean. If 

a stranding response can be mounted quickly and safely and the animals are assessed and 

deemed healthy, individuals of a mass stranding may be released or relocated for immediate 

release. However, some individuals may be admitted into rehabilitation and may be 

“Conditionally Releasable” based on the pathologic findings of the pod mates that perished 

during the event. 
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9. The animal was transferred from a research facility or undergoing permitted research 

during rehabilitation – Research activity may extend the frequency and intensity of 

handling time and could increase the risk of altering behavior or increasing the chance of 

exposure to facility pathogens or chemicals (e.g., anesthetic agents, metabolic agents, etc). 

These animals will be considered “Conditionally Releasable” or “Nonreleasable.” 

3.4 Developmental Assessment of Cetaceans 

A fundamental criterion for developmental clearance of a rehabilitated cetacean is that it has attained 

a sufficient age to be nutritionally independent, including the ability to forage and hunt. The cetacean 

calf grows from a state of total nutritional dependence through nursing to partial maternal dependence 

as it learns to forage for fish and/or squid. Eventually the young cetacean achieves total nutritional 

independence and forages completely on its own. Factors including individual and species variations, 

rehabilitation practices, health status, plus environmental factors affect the rate at which such 

development occurs (see Appendix I for Developmental Stages by Cetacean Species). For bottlenose 

dolphins (Tursiops truncatus), the age at which a calf may be completely weaned is approximately 1-

4 yrs. Calves that are nutritionally dependent at the time of admission to rehabilitation are 

automatically placed in the “Conditionally Releasable” category and must be discussed with NMFS. 

In situations where a nursing, dependent calf strands with its mother and both animals achieve 

medical, behavioral and ecological clearance, the calf must be released with its mother. Very young 

nursing calves that strand alone or whose mothers die may lack socialization and basic acquired 

survival skills as they grow older. Neonatal and very young nursing calves will be deemed “NonReleasable.” Cases involving older calves and juveniles having some foraging skills may be 

considered “Conditionally Releasable” but require a thorough assessment and optimum planning for 

release and subsequent monitoring. 

Reproductive status in and of itself does not impact release candidacy unless a female strands with its 

calf or gives birth during rehabilitation. For instance, a single pregnant female should be returned to 

the wild as soon as both medical and behavioral clearance has been achieved and NMFS approves of 

the release plan. However, all mother-calf cetacean pairs are deemed "Conditionally Releasable" and 

must be fully discussed with NMFS and its advisors. The well-being of both the mother and the calf 

is to be carefully considered in such cases. Efforts should be made to reduce their time in captivity 

and to keep the mother-calf pair together, yet allow for continued treatment and rehabilitation of both 

individuals if warranted. 
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 Cases involving cetaceans showing signs of advanced age are considered "Conditionally Releasable" 

and should also be thoroughly evaluated and discussed with NMFS. Although it is not always feasible 

to precisely determine the age of a living adult cetacean, the physical condition of the animal may 

suggest to the Assessment Team that it is geriatric. Geriatric animals may have underlying clinical 

conditions that contributed to their stranding or may be behaviorally or ecologically unsuited for 

continued life in the wild. 

3.5 Behavioral Assessment of Cetaceans 

Complete assessment of the behavior and ecological potential may be limited by the confines of a 

temporary captive environment and behavior of the animal will differ from that displayed in the wild. 

A full understanding of what constitutes “normal” for a given cetacean species also may be lacking. 

Behavioral and ecological clearance is thus founded on evaluation of basic criteria necessary for the 

survival of the animal in the wild. Behavioral evaluation often overlaps with medical evaluation as 

abnormal behavior may indicate an underlying disease process. Experts with species specific 

knowledge of cetacean behavior and ecology, in addition to the attending veterinarian, should assess 

the behavior of the rehabilitated cetacean. These assessments should involve closely evaluating and 

documenting behavior throughout rehabilitation (i.e., ethogram), relating the behavioral, sensory, and 

physical capabilities of the animal to its prospects of surviving and thriving in the wild. 

To achieve basic behavioral clearance, a cetacean should breathe normally, including rate, pattern, 

quality, and absence of respiratory noise. A cetacean should swim and dive effectively without 

evidence of aberrant behavior or auditory or visual dysfunction that may compromise its survival in 

the wild or suggest underlying disease that may threaten wild marine mammals. Behavioral clearance 

also should include confirmation that the cetacean is able to recognize, capture, and consume live 

prey when such tests are practical (for example, it may not be possible to obtain live prey for offshore 

or deep water species). Documented dependency on or attraction to humans and human activities in 

the wild would warrant special consideration as a possible conditional release or non-release decision. 

Basic behavioral conditioning of wild cetaceans for husbandry and medical procedures may be 

necessary during rehabilitation as long as every effort is made to limit reinforced contact with 

humans. Station training may be necessary to assure animals are appropriately fed and to control 

social dominance when multiple animals are being treated in the same pool or pen. Also, such 

conditioning may reduce stress for the animal during examinations and acquisition of biological 

samples. Behavioral conditioning of cetaceans is to be done for the shortest time necessary to achieve 
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rehabilitation goals and is to be eliminated prior to release such that association of food rewards with 

humans is diminished. Additional information on behavioral conditioning of marine mammals is 

provided in the references. 

3.5.1 Breathing, Swimming, and Diving 

The Assessment Team should evaluate respiration at the pre-release exam to determine that the 

animal does not exhibit abnormal breathing patterns or labored breathing. Respiratory measurements 

should be standardized to record the number of breaths per five-minute intervals. Evaluation of 

swimming and diving should confirm that the cetacean moves effectively and does not display 

abnormalities such as listing, difficulty submerging, asymmetrical motor patterns, or other potentially 

disabling conditions. In small pools (i.e., less that 50 ft diameter), cetaceans may not be able to 

demonstrate a full range of locomotor and maneuvering abilities; therefore, evaluation in larger pools 

is highly recommended. Cetaceans exhibiting persistent abnormalities of breathing, swimming, or 

diving, are to be considered “Conditionally Releasable” or “Non-releasable” and must be discussed 

with NMFS. 

3.5.2 Aberrant Behavior 

The behavioral clearance of the cetacean should include confirmation that the animal does not exhibit 

aberrant behavior. Examples of aberrant behavior include, but are not limited to, regurgitation, head 

pressing, postural abnormalities such as repetitive arching or tucking, decreased range of motion, 

abnormal swimming or breathing as described above or excessive interest in interaction with humans. 

Cetaceans displaying abnormal behavior may have an underlying disease process or may have 

permanent injury or tendencies that will decrease their chance of survival in the wild. Cetaceans 

displaying aberrant behavior are considered “Conditionally Releasable” or “Non-releasable” and thus 

are to be fully discussed with NMFS. 

3.5.3 Auditory and Visual Acuity 

The behavioral and ecological clearance of the cetacean should include evaluation of auditory and 

visual acuity. Auditory dysfunction, involving production or reception of typical sounds or signals 

occurring in the wild, may be a reflection of active disease, permanent injury, or degenerative 

changes associated with aging. Evaluators may suspect that a cetacean has compromised auditory 

function if it appears to have difficulty locating prey items or various objects via echolocation or if it 

minimally responds to novel noises. Reduced auditory abilities can compromise the ecological 
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functionality and social abilities of some species, thus reducing the probability of survival in the wild. 

In each case, it is highly recommended that hydrophone-recording systems with an appropriate 

frequency response be used to record sound production in the water to document production of 

normal classes and qualities of sounds made by the cetacean. It is important to evaluate hearing if 

there are signs of compromised auditory function and diagnostic testing such as auditory evoked 

potential (AEP) may be necessary to further evaluate the anima. Such testing requires approval and 

coordination with NMFS. Cetaceans having discoloration, swelling, abnormal shape, position or 

appearance of the eye or eyelids may have visual dysfunction and also require discussion with NMFS. 

3.5.4 Prey Capture 

The rehabilitated cetacean should demonstrate foraging behavior (i.e., the ability to hunt and capture 

live prey) prior to its release when practical. Normal consumption of solid food should also be part of 

the medical assessment. This demonstrates the ability to swallow and that there is no pharangeal 

and/or gastrointestinal abnormalities. This evaluation is especially important for young and geriatric 

animals. Prey items normally found in the animal’s environment and of good quality should be used 

whenever possible. Natural prey items may not be available for rehabilitating pelagic cetacean 

species; evaluators may try to utilize other prey species. However, many cetaceans often will not 

consume non-prey species. For social species, it may be just as important to look for cooperative or 

coordinated feeding behavior. NMFS should be notified if a rehabilitated cetacean appears 

compromised in its ability to recognize and/or capture live prey or if logistical issues preclude 

assessment of this behavior. 

Cetaceans that are believed to have had limited foraging experience prior to stranding (i.e., young 

juveniles) require particularly careful assessment of prey capture ability. This behavior is learned and 

cetaceans that strand at a young age may not have gained adequate foraging skills to sustain 

themselves in the wild. Also, knowledge of the natural history of the species may be useful. If the 

species forages and hunts as a social unit, this may affect its ability to survive in the wild if released 

as a solitary animal. Similarly, amputated appendages may preclude the use of some specialized 

feeding techniques or attainment of sufficient speed or maneuverability for prey capture, or 

diminished auditory function may prevent individuals that prey on soniferous (i.e., noise-producing) 

fishes from locating sufficient prey to survive (e.g., coastal bottlenose dolphins). 
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3.5.5 Predatory Avoidance 

Testing a cetacean’s ability to avoid predators is not practical in most cases, but indirect evidence of 

abilities can be evaluated. If the individual is determined to have stranded primarily as a direct result 

of a shark attack (as opposed to secondarily, as an attack on an otherwise compromised animal), then 

this suggests that the animal may lack the skills or physical abilities to continue to survive in the wild. 

This would be especially important in the case of young animals, recently separated from their 

mothers. For social species, observations of group behavior may indicate the cohesiveness of the 

group which is an important behavioral mechanism for predatory avoidance. 

3.5.6 Social Factors 

The survival of an individual cetacean may be critically dependent on social organization and 

conspecifics (see Appendix I for Cetacean Species Specific Group Occurrence). A tremendous range 

of variability of sociality exists across the cetaceans. Members of species involved in mass strandings 

(i.e., presumably a social species) should not be rehabilitated singly or in unnatural social groups. 

The composition of these groups should be carefully considered when animals are recovered from a 

stranding and considered for release. It would be naïve to assume that any two cetacean species can 

be put together to form a functional social unit or that even two unfamiliar members of the same 

species will bond into a functional social unit. Therefore, for social species it is important to assess 

the group dynamics and behavior (reasonable social group) in the same manner as for individuals. 

Cetaceans that do not live in social groups do not necessarily require conspecifics for release, as long 

as they are released into an appropriate habitat where conspecifics are likely to occur. Indications of 

social problems that may be a contributing factor of the stranding (e.g., evidence of extensive fresh 

tooth raking marks in the absence of other medical factors) and should be considered. Other factors 

that are important for proper socialization and should be evaluated include hearing, sound production, 

missing appendages, and missing teeth. 

3.6 Medical and Rehabilitation Assessment of Cetaceans 

The medical assessment includes information related to any diagnostic testing, treatment, and 

response to treatment. The attending veterinarian should perform a hands-on-physical examination 

upon admission and prior to the release determination. The attending veterinarian should review the 

animal’s complete history including all stranding information and diagnostic testing, and medical and 

husbandry records. The primary goal of the testing required by NMFS is to determine the risk to the 

health of wild marine mammal populations. This is achieved by testing for diseases that pose a 
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significant morbidity or mortality risk to wild populations (i.e., reportable diseases). Those that are 

zoonotic or a public health and safety concern require immediate NMFS notification to assure proper 

protocols are put into place. Additional testing will be required if the animal was part of an official 

UME or suspected anthropogenic exposure (e.g., acoustic insult, hazardous waste spill, etc.). NMFS 

may request testing for other emerging diseases to support surveillance for potential epidemics of 

concern and to monitor changes in disease status due to rehabilitation practices. The directive for the 

pre-release health screen will come from the NMFS Regional Stranding Coordinator through the 

MMHSRP. Appendix D lists diseases of concern for cetaceans. 

A complete health screen should be completed upon admission and just prior to release including 

basic blood collection for a CBC, chemistry profile (including BUN and creatinine, enzymes and 

electrolytes), serology, microbial and fungal culture (i.e., blow hole, rectal, ocular, and lesions), 

cytology, urinalysis, and fecal exam. If the animal is female and at reproductive age, it is advisable 

that pregnancy be determined as soon as possible to avoid potentially fetal toxic medication. Serum 

(3ml/each) should be banked at the time of admission and just prior to release for retrospective 

studies. Cessation of antibiotics should occur two weeks prior to release examination to assure that 

the animals is no longer dependant on the medication and that the drug has cleared based on the 

pharmacokinetics and requirements made by the veterinary community and the Food and Drug 

Administration. Some antibiotics clear the body quickly and require shorter withdrawal time. When 

this recommendation cannot be met, seek advice from NMFS. The attending veterinarian should 

provide written notification to the NMFS Regional Stranding Coordinator that a health screen 

and assessment of the cetacean has been performed. The notification must also include the final 

release plan and a plan for hands-on physical examination by the attending veterinarian 

(including last blood draw and evaluation) within 72 hours of its release. The required 

documentation and signed release determination will be part of the administrative record along 

with the signed (by the NMFS Regional Administrator) letter of concurrence approval for 

release. 

It is of extreme importance that the cetacean be monitored closely for disease throughout its 

rehabilitation. Regardless of the stranding etiology, handling and care can stress the animal 

increasing its susceptibility to disease. If not properly managed, rehabilitation facilities provide an 

environment where mutated or novel pathogens not typically encountered in the wild can easily be 

transmitted from animal to animal. This scenario can become problematic if an animal is exposed 

during rehabilitation and may carry a pathogen to a naïve wild population upon release. Introduction 
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of pathogens from rehabilitation centers to the wild is a concern as diseases with serious epizootic 

potential have previously been detected (Measures 2004, Moore et al. 2007, and Stoddard et al. in 

press). During rehabilitation, infectious agents may become altered (i.e., change in virulence and 

infectivity) as they pass through new hosts or mix with other microbes and potentially result in a 

multi-antibiotic resistance strain. 

The attending veterinarian is urged to utilize the full spectrum of diagnostic modalities available for 

health assessment of the cetacean. In addition to the complete health screen analyses, advanced 

techniques for pathogen detection such as PCR and toxicology analyses are available. A number of 

diagnostic imaging techniques including radiology, CAT scans, and MRI may be used as well as 

bronchoscopy and laparoscopy. The cetacean literature has expanded to include numerous references 

on the performance and interpretation of diagnostic tests. 

3.7 Release Site Selection for Cetaceans 

Ideally, the rehabilitated cetacean is released into its home range, genetic stock, and social unit. For 

species such as coastal resident bottlenose dolphins, returning the animal to its exact home range may 

be extremely important. For widely ranging species such as the pilot whale, specificity of the release 

site may be less critical as the genetics of these cetaceans may be more panmictic. Returning the 

animal to its home range or species range may increase the likelihood that the animal will have a 

knowledge of available resources, potential predators, environmental features, and social relationships 

that would support its successful return to the wild. Consideration should also be given to the time of 

year, since the range of the animal may change based on season and where conspecifics are along 

their migration route at a given point in time. 

In many cases, the precise home range of the individual will not be known. There may not be any 

information regarding the animal’s social unit or its individual ranging patterns prior to its stranding. 

In some cases, photographic identification records may help identify the home range or social group 

for some species. When the home range of the cetacean is unknown, the animal should be released at 

a location near to its stranding site that is occupied regularly by its conspecifics, ideally those of the 

same genetic stock. Genetic analyses of a tissue sample via a qualified laboratory and appropriate 

tissue archive may aid with determining the appropriate stock of origin. Pelagic cetaceans are to be 

released offshore into a habitat occupied by conspecifics at that time of year. For animals that mass 

strand, depending on the life history, social units should be maintained whenever possible thus 

cetaceans that stranded together should be released together as a group. Because much of cetacean 
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behavior is learned, juveniles should be released with adults or in the presence of conspecifics and 

mothers with their dependent young. 

Other factors to be considered in release site selection are availability of resources and condition of 

the habitat. NMFS and the Stranding Network Participant are to ensure that severely depleted 

resources or degraded habitat at the release site do not pose an obvious threat to the released animal. 

Release plans should include alternative release sites or schedules if there is a substantial decline in 

resources or habitat quality such as massive fish kills, significant declines in commercial and/or 

recreational fish landings, harmful algal blooms, or high concentrations of environmental 

contaminants. Animals should not be released into areas of dense public use and/or high commercial 

and recreational fishing activity. 

3.8 Marking for Individual Identification of Cetaceans Prior to 

Release 

Three forms of identification have routinely been used for cetaceans including photo-identification 

(documenting individual identifying physical characteristics such as scars, color pattern, dorsal fin 

shape, etc.), freeze branding, and dorsal fin tags. NMFS recommends the use of all three forms of 

identification for all releases. For delphinids, photo-identification should include body, face, dorsal 

fin, flukes, and pectoral flippers. Numerical freeze brands should be at least 2” high and may be 

placed on both sides of the dorsal fin and/or on the animal’s side just below the dorsal fin, except for 

species that lack a dorsal fin or have small dorsal fins such as the harbor porpoise. Roto-tags should 

be attached on the trailing edge of the dorsal fin. Tag application and freeze branding should only be 

done by experienced personnel as improper tagging may cause excessive tissue damage, infection, or 

premature loss of the tag or mark. Marking of non-delphinid cetaceans can be more challenging due 

to unique anatomical features and should be determined in consultation with NMFS. NMFS must 

receive advance notification of and approve any additional forms of identification that a rehabilitation 

facility voluntarily wants to place on a cetacean besides those mentioned above. NMFS authorization 

is required prior to placement of VHF radio or satellite-linked radio tag. 

The identification system to be used on cetaceans deemed “Conditionally Releasable” must be 

approved by NMFS. As these animals are required to have an advanced post-release monitoring plan, 

conditionally releasable cetaceans will often require VHF or satellite tagging in addition to photoidentification, freeze-branding, and placement of a visual fin tag. 
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3.9 Post-Release Monitoring of Cetaceans 

Few data is currently available regarding the long-term fates of released cetaceans. Post-release 

monitoring provides essential information to develop and refine marine mammal rehabilitation and 

release practices. “Conditionally Releasable” cetaceans should be monitored daily for at least two 

months after release. The specific post-release monitoring plan for each cetacean is to be coordinated 

through NMFS. Post-release monitoring methods may include visual observations from land, sea, or 

air, and/or radio or satellite-linked monitoring. It is understood that post-release monitoring of 

cetaceans, particularly pelagic species, is an extensive undertaking for which significant support is 

required, often from multiple sources. In a few instances, NMFS has provided resources such as 

financial support, personnel, and equipment for post-release monitoring but it is not standard practice. 

Therefore, the rehabilitation facility is encouraged to seek funding to enhance their post-release 

monitoring program. 

The first month after release is a particularly critical period during which it will become evident 

whether the animal is thriving, including avoiding predators, capturing sufficient prey, and being 

accepted by conspecifics. For coastal species it is recommended that monitoring continue on a 

regular basis for at least one year. Funding resources, such as the Prescott Grant Program, can assist 

with the financial burden of such endeavors. NMFS requires periodic and final reports on released 

animals. These reports will facilitate future revisions to the marine mammal rehabilitation and release 

guidelines. In order to compare individual cases, standardization of data collection protocols for 

monitoring released cetaceans will be required. NMFS will provide the stranding network with the 

desired format for receipt of tracking data in reports. Presentation, discussion, and formal study of 

monitoring data and its dissemination to the stranding network will aid in the assessment of cetacean 

rehabilitation and release programs. 

Release plans should include the contingency plans that are available for recovering the animal, 

should monitoring indicate its failure to thrive. The release plans should also address treatment and 

euthanasia if the animal is retrieved or restrands. In addition, NMFS may require such contingency 

plans for “Conditionally Releasable” cetaceans, depending on the circumstances. 
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3.10 Decision Tree – Cetacean Release Categories

3.10.1 Releasable 

The cetacean is cleared for release by the attending veterinarian (including the Assessment Team) and 

the NMFS Regional Administrator concurs in writing. This means that the requirements for the 

health and behavior assessment, marking/tagging, and release plan have been met and both veterinary 

and biological opinions regarding release have been received (see text for details). For an animal to 

be considered “releasable” the response to all of the essential release criteria below should be met. 

History 

Cetacean has no historical information requiring consultation with NMFS such as stranding in close 

temporal or geographic relation to a UME, stranding associated with an environmental event of 

concern,, an acoustic insult, a human interaction or criminal investigation, or a mass stranding. 

Developmental Stage/Life History

a) Cetacean has attained sufficient size and age to be nutritionally independent. 

b) Cetacean is not a female with calf. 

c) Cetacean is not a geriatric animal and not compromised due to age related conditions. 

d) Cetacean was not exposed to captive or domestic animals during rehabilitation. 

Behavioral Clearance

a) Cetacean breathes normally, swims and dives effectively. 

b) Cetacean does not exhibit aberrant behavior, auditory, or visual deficits. 

c) Cetacean demonstrates appropriate foraging ability. 

d) Cetacean did not strand as direct result of a failure to avoid predators. 

e) Cetacean did not strand as a result of taking food from humans in the wild. 

f) Cetacean did not strand as a direct result of a demonstrated inability to obtain sufficient food 

in the wild. 

g) Cetacean did not strand as a direct result of conspecific injury. 
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Medical Clearance

a) Health status of the cetacean is deemed appropriate for release by the attending veterinarian. 

b) Hands-on physical exam by the veterinarian at time of admission to rehabilitation and within 

72 hours of release. 

c) Laboratory tests performed at time of admission and within seven days of release are 

complete and submitted for review: 

• CBC; 

• Chemistry Profile to include: Glucose, Sodium, Potassium, Chloride, Calcium, 

Phosphorus, Iron, Bicarbonate, Alkaline Phosphatase, ALT, AST, GGT, BUN, 

Creatinine, Uric Acid, CPK; 

• Serum Banking (3 ml upon admission and 3 ml at time of release, more if available; 

and 

• Aerobic Bacterial Cultures (Blowhole, Rectal, Lesions). 

d) Cetacean is free of drugs (excluding sedatives used for transport) a minimum of 2 weeks prior 

to release. 

Release Logistics

a) Tagging/Marking - Delphinids: 3 forms of identification approved by NMFS (dorsal fin tag, 

freeze brand, photo, other). 

b) Release Site - Return to appropriate stock and geographical site under favorable 

environmental conditions, and for social species, introduced in areas with conspecifics. 

c) Tracking - minimum of 2 months post-release monitoring coordinated with NMFS (provide 

NMFS with regular tracking updates). 

d) Provide NMFS a report at the end of the tracking period. 

3.10.2 Conditionally Releasable 

The cetacean did not meet one or more of the essential release criteria but may be releasable in the 

future pending resolution of the problems identified by the attending veterinarian and Assessment 

Team.. This may involve discussion with outside experts in consultation with NMFS. Contingency 

plans for recapture, treatment, permanent care, and euthanasia should be required if release is 

unsuccessful and the animal restrands. The following may be true for one or more assessment points. 
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History

a) Cetacean stranded in close temporal or geographic relation to a UME. 

b) Cetacean stranded in association with an environmental event of concern or an anthropogenic 

acoustic insult. 

c) Cetacean was involved in a mass stranding. 

d) Cetacean stranded previously on one or more occasions. 

e) Single stranding of a social species. 

f) Cetacean was part of a NMFS permitted research project, potentially being handled more 

frequently. 

Developmental Stage/Life History 

a) Cetacean is nutritionally dependent, but older calf with some foraging skills. 

b) Cetacean is recently weaned. 

c) Cetacean is a female with calf. 

d) Cetacean is a geriatric animal and is compromised due to age related conditions. 

Behavioral Assessment 

a) Cetacean exhibits aberrant behavior, which may include but is not limited to, abnormal 

breathing, swimming, and/or diving, auditory or visual dysfunction. 

b) Ability of the cetacean to forage for prey is questionable or logistical circumstances prevent 

testing of forage or prey capture ability. 

c) Cetacean requires significant conditioning due to developmental stage and/or medical 

condition. 

d) Predator wounds were likely secondary to another cause of the stranding. 

e) Attraction to humans in the wild has been extinguished. 

f) Cetacean is a social species and has stranded due to injury from conspecifics. 

Medical Assessment - The attending veterinarian determines that the health status of the cetacean is 

uncertain regarding suitability for release. The veterinarian arrives at a determination of 

“Conditionally Releasable” through performance and interpretation of physical examinations and 

interpretations of tests such as CBC, chemistry profile, cultures, and other tests required by NMFS, 

plus any other diagnostic tests deemed necessary to fully evaluate the animal. Response of the 

cetacean to therapy and the clinical judgment of the veterinarian may also contribute to a 
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determination of “Conditionally Releasable.” Further tests may be required including ultrasound or 

radiographs to clarify medical issues. 

Cetaceans exhibiting any of the following medical or physical conditions are to be discussed with 

NMFS, with the expectation that without resolution, such conditions will make the animal an 

unsuitable candidate for release: 

a) Compromised function of sensory systems (auditory, visual). 

b) Decreased range of motion. 

c) Deformed or amputated appendage. 

d) Laboratory tests interpreted as abnormal or suspicious of disease (CBC, chemistry, cultures, 

or other tests). 

Release Logistics

a) Tagging, marking, post-release monitoring - Extensive post-release monitoring of cetaceans 

deemed "Conditionally Releasable" is required and is to be approved and coordinated through 

NMFS. Post-release monitoring of such animals should be at least two months duration, 

likely longer. Monitoring is likely to include advanced tracking techniques, such as satellite 

tracking via radio-tracking or photographic identification searches if the animal is likely to 

move outside of the range of monitoring. The cetacean will continue to be deemed 

"Conditionally Releasable" until the post-release monitoring plan required by NMFS can be 

implemented. 

b) Stock of origin is unknown, uncertain, or temporarily unreachable due to environmental or 

natural history factors - When such circumstances exist, the case is to be discussed with 

NMFS. The cetacean will be deemed "Conditionally Releasable" until specifics of release are 

approved by NMFS. 

c) Plan for recapture - NMFS may request a contingency plan if feasible for a "Conditionally 

Releasable" cetacean prior to its release should the animal appear to be unable to readjust to 

the wild. This should include plans for follow up treatment, permanent care and/or 

euthanasia. The cetacean will continue to be deemed "Conditionally Releasable" until NMFS 

approves a contingency plan. 
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3.10.3 Non-Releasable 

The cetacean is determined to be unsuitable for release by the attending veterinarian and Assessment 

Team and the NMFS Regional Administrator concurs. The animal did not meet the essential release 

criteria, and thus does not have a reasonable chance of survival in the wild or poses health risks to 

wild marine mammals. 

History

a) Cetacean has been in captivity for more than two years or is otherwise too habituated and 

counter-conditioning techniques have been unsuccessful. 

b) Cetacean stranded previously on one or more occasions. 

c) Cetacean was part of a NMFS permitted research project, potentially being handled more 

frequently, and circumstances preclude its suitability for release. 

Developmental Stage/Life History

a) Cetacean is nutritionally and socially dependent (neonate and young nursing calf without 

foraging skills). 

b) Cetacean is geriatric and exhibiting other medical and/or behavioral abnormalities. 

Behavioral Clearance

a) Exhibits abnormal breathing, swimming, diving, or other aberrant behavior that may 

compromise survival in the wild or may be caused by a disease of concern to wild marine 

mammals. 

b) Exhibits auditory or visual dysfunction that would compromise survival in the wild or may be 

caused by an ongoing disease process of concern to wild marine mammals. 

c) Unable to capture and consume live prey. 

d) Demonstrated inability to avoid predators. 

Medical Clearance - The attending veterinarian determines that the health of the cetacean precludes 

release. In such cases, the medical condition of the animal prevents normal function to a degree that 

would compromise its survival in the wild or pose a health risk to wild marine mammals. The 

veterinarian supports the determination of “Non-Releasable” status with required physical 

examinations and tests such as CBC, chemistry profile, cultures, and those required by NMFS plus 

any other tests deemed necessary to fully evaluate the animal. Further tests may be required, 
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including ultrasound or radiographs, to clarify medical issues. The veterinarian presents their 

findings to the NMFS Regional Stranding Coordinator and recommends that the cetacean be 

maintained in captivity or be euthanized. 

Conditions that warrant consideration that a cetacean is deemed “Non-Releasable” include, and are 

not limited to, the following: 

a) Compromised function of sensory systems (auditory, visual). 

b) Decreased range of motion. 

c) Deformed or amputated appendage. 

d) Laboratory tests interpreted as abnormal or suspicious of disease of concern. 

e) Geriatric, or believed to have chronic disease, which may compromise survival in the wild. 

Release Logistics

a) Tagging/Biomonitoring - The cetacean requires extensive post-release monitoring for which 

there are insufficient resources.
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4. Guidelines for Release of Rehabilitated Pinnipeds 

4.1 Introduction 

Each year in the United States, several different species of pinnipeds from three taxonomic families, 

Phocidae (true seals), Otariidae (eared seals), and Odobenidae (walrus), are rescued and rehabilitated. 

As walrus are under the jurisdiction of FWS, these guidelines should be generally applied but there 

are a few exceptions. Close consultation with FWS is required with each walrus case. 

Except as otherwise noted, each pinniped is required to have a complete historical, developmental, 

behavioral, and medical status assessment by the attending veterinarian and animal care supervisor 

and be properly marked for identification prior to release. The release determination recommendation 

must include a signed statement from the attending veterinarian in consultation with the Assessment 

Team that the animal is medically and behaviorally suitable for release in accordance with the 

release criteria and include a written release plan and timeline. NMFS or FWS may require 

additional testing for reportable diseases in light of new findings regarding various disease and health 

issues and this information should be included in the release request. A release plan will require a 

justification statement and detailed description of the logistics for transporting, tagging, location, 

timing, crowd control, media coordination (if applicable), post release monitoring, and recovery 

should the animal fail to thrive (e.g., restrands). NMFS or FWS may require recapture if the animal 

appears to be in distress following a specified time after release. Recapture will require special 

authorization from NMFS or FWS prior to this activity. NMFS or FWS may consult with individual 

experts for further guidance. NMFS reserves the right to impose additional requirements in the 

release plan as stated in 50 CFR 216.27 (a)(3). 

The NMFS Regional Administrator may allow for pre-approved waivers for routine pinniped cases as 

stated in 50 CFR 216.27(a)(2)(i)(A). Typically these cases are anticipated (e.g., the typical annual 

cluster of cases where the etiology is known and diagnosis and treatment is routine) and can be 

appropriately planned. For such waivers, the Stranding Network Participant should submit a protocol 

for such cases including location of release. These waivers will require pre-approval by the NMFS 

Regional Administrator on a schedule as prescribed in the Stranding Agreement. NMFS may require 

that a certain percentage of these cases that present with similar clinical signs and diagnosis be 

thoroughly tested and assessed each year. Similarly, NMFS may give blanket authorization for preapproved release sites and for post-release monitoring plans. 
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4.2 Overview of Release Categories for Pinnipeds 

Pinnipeds evaluated at rehabilitation facilities can be grouped into one of three “Release Categories” 

based on historical, developmental, behavioral, ecological, and medical criteria set forth in a 

standardized checklist. It is recommended that the standardized checklist (see Appendix J) should 

be used to assess and document the release candidacy of rehabilitated pinnipeds. The checklist 

includes a health statement (i.e., health certificate) to be signed by the attending veterinarian and 

authorized representative, which verifies that a pinniped meets appropriate standards for release. This 

checklist could be used to determine and document releasability (i.e., as part of the required 

documentation sent to NMFS) and as a final check just prior to release. 

The majority of walrus typically strand as calves and are not good release candidates due to the 

extended period of maternal dependency. FWS generally considers walrus calves to be “nonreleasable” and considers all stranded walrus on a case-by-case basis for permanent placement. If the 

animal is placed in permanent captivity, the receiving facility must hold an Exhibitor’s License from 

APHIS [7 U.S.C. 2131 et seq.] and comply with MMPA (16 U.S.C. 1374 §104(c)(7)). Questions 

regarding disposition of stranded walrus should be directed to the FWS contact as identified in 

Appendix H. 

1. "RELEASABLE": There are no significant concerns and the animal meets basic historical, 

developmental, behavioral, ecological, and medical criteria, supporting the likelihood of 

survival and a lack of risk to the health of wild marine mammals. The release plan (postrelease identification, release site, contingency plans, and post-release monitoring) has been 

approved in writing by NMFS via the letter of concurrence. For the pinniped to be deemed 

“Releasable,” all items on the checklist should be answered as "Yes." The attending 

veterinarian signs the checklist confirming the information and the assessment. 

2. "CONDITIONALLY RELEASABLE": One or more items on the standardized checklist 

have been marked "No" for pinnipeds in this category. This may pertain to historical, 

developmental, behavioral, ecological, and/or medical status concerns regarding the animal’s 

potential to survive in the wild and/or its potential to pose a health risk to other marine 

mammals. A pinniped may also be deemed conditionally releasable if requirements for 

release cannot be met at present but may be met in the future and without compromising the 

health and welfare of the individual animal. In such cases, more time may be needed to 
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determine the feasibility of release (see 50 CFR 216.27(a)(1)(iii) for species under NMFS 

jurisdiction). 

All “Conditionally Releasable” pinnipeds must be discussed with NMFS or FWS. NMFS or 

FWS may consult with individual experts to discuss specific cases. Experts include scientists 

and veterinarians with expertise in pinniped biology and medicine (particularly experts with 

species specific knowledge). Such discussions will clarify the most appropriate disposition. 

For example, additional medical testing, rehabilitative therapy, and additional strategies for 

post-release monitoring may be required to release a "Conditionally Releasable" pinniped. 

3. "NON-RELEASABLE": One or more items on the standardized checklist have been 

marked "No" for pinnipeds in this category. This may pertain to historical, developmental, 

behavioral, ecological, and/or medical status concerns that preclude release to the wild. It has 

a documented condition demonstrating little chance for survival in the wild and/or a 

diagnosed health risk to wild marine mammals. For NMFS species, this category also 

includes animals that have been in rehabilitation greater than two years (see 50 CFR 

216.27(a)(1)(iii)). Additionally, a pinniped may be deemed “Non-Releasable” if an 

appropriate release site or post-release monitoring plan cannot be arranged. Rehabilitation 

facilities that believe that they may have a walrus that is non-releasable must contact the FWS 

Marine Mammals Management Office (as identified in Appendix H) for concurrence on this 

finding and eventual disposition of the animal. If FWS determines that a walrus is nonreleasable, the holding facility may request a permit for permanent placement of the animal as 

long as the facility meets the requirements under section 104(c)(7) of the MMPA. 

For animals deemed “Non-releasable” and with the concurrence from the NMFS Regional 

Administrator, the animal can be permanently placed in a public display or research facility 

or euthanized. If the animal is to be placed in permanent captivity, the receiving facility must 

be registered or hold a license from APHIS [7 USC 2131 et seq.] and comply with MMPA 

(16 USC 1374 Section 104(c)(7)). Facilities wishing to obtain non-releasable animals should 

send a Letter of Intent to NMFS PR1 to permanently retain (i.e., if affiliated with the 

rehabilitation facility) or acquire the animal. This letter should include a signature of the 

“Responsible Party of Record”. As part of the decision making process will consult with 

APHIS and may review the qualifications and experience of staff, transport, and placement 

plans (i.e., integration based on appropriate composition of species, sex, and age and the 

intended proposed plan for public display or scientific research). Once approved, NMFS PR1 
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will respond with a Transfer Authorization Letter and include MMDS, OMB Form 0648-

0084, to be returned to NMFS PR1 within 30 days of transfer. Upon receipt of the MMDS, 

NMFS PR1 will acknowledge the transfer in writing and return updated MMDS to the 

receiving facility. 

4.3 Historical Assessment of Pinnipeds 

Historical stranding information may guide the management of rehabilitation and the plan for postrelease monitoring. Important historical information should include: 

1. A record of previous stranding - Pinnipeds that have previously stranded and been released, 

and subsequently strand again, are deemed “Conditionally Releasable” pending consultation 

with NMFS or FWS. Such animals should be reassessed as they may have underlying health 

issues requiring additional evaluation, diagnostic testing, and advanced post-release 

monitoring. Alternatively, such pinnipeds may be assessed as “Non-Releasable” and be 

transferred to permanent captivity or euthanized. 

2. An association with an ongoing epidemic among other animals or with a UME - If the 

stranding of a pinniped occurs in close temporal or geographic proximity to a UME, fish kill, 

harmful algal bloom, hazardous waste spill, or other such environmental event, the pinniped 

is deemed “Conditionally Releasable” and consultation with NMFS or FWS is required. The 

agencies may request additional testing, documentation, and/or post-release monitoring of 

such pinnipeds. 

3. Stranding location and active or home range - Areas that are worth assessing are increased 

human activity (e.g. active fishery, increased recreational use, military activity, shipping 

activity, etc.) or hazardous environmental conditions (e.g., harmful algal bloom or hazardous 

waste spill, and/or special weather conditions like El Niño, hurricane, extreme cold, extreme 

heat, etc). During an El Niño event, the rehabilitation center should consult with NMFS 

regarding management and release of the animal because unfavorable environmental 

conditions may persist once an animal is ready for release and thus the animal should be 

deemed “Conditionally Releasable.” Also, the geographical distance between the stranding 

location and the rehabilitation facility is important to acknowledge as there could be 

important differences in the microflora at the facility. Information on areas of human activity 

and environmental hazards is also vital for determining an appropriate release site. 
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4. The animal was exposed to (or injured by) other wild or domestic animals - Pinnipeds 

having a history of exposure (i.e., confirmed or suspected) to terrestrial wild or domestic 

animals are deemed “Conditionally Releasable” and must be discussed with NMFS or FWS. 

Pinnipeds may contract disease from terrestrial wild or domestic animals such as foxes or 

dogs. For instance, canine distemper represents a serious health threat to pinnipeds. Should a 

rehabilitating pinniped contract such an pathogen, it could transmit the illness to its wild 

cohorts. Such transmission of pathogens can occur even when a rehabilitated pinniped is not 

showing clinical signs of disease. Consultation with NMFS or FWS is thus required for 

pinnipeds that have a history of exposure (i.e., confirmed or suspected) to terrestrial animals. 

5. The animal has a record of attacking or biting a human - Pinnipeds that have inflicted a 

bite (including mouthing of unprotected skin) of a human are deemed “Conditionally 

Releasable” and must be discussed with NMFS or FWS. A variety of infectious diseases may 

be transmitted from animals to humans via bite wounds. Although documentation of rabies 

among pinnipeds is rare (there is one published case of rabies in a ringed seal from the 

Svalbard Islands, Norway [Odegaard and Krogsrud 1981]) the fatal outcome of this disease in 

humans warrants careful consideration of factors surrounding pinniped bites to people. 

NMFS or FWS may require consultation with state public health officials regarding pinnipeds 

that inflict bites on humans and may request that the facility follow state policies and 

guidelines for unvaccinated non- domestic animal bites. NMFS may also impose quarantine 

or additional diagnostic testing requirements prior to authorizing release. 

6. The animal was evidence or part of a human interaction or criminal investigation – This 

includes an investigation by NOAA Office of Law Enforcement, the U.S. Department of 

Justice, or other Federal, state or local authorities. 

7. The animal was transferred from another holding, triage or rehabilitation facility – The 

opportunity for exposure to pathogens can occur at different stages of response and 

rehabilitation. Therefore, it is important to obtain medical records and document the quality 

of care and treatment at each stage of this process. 

8. The animal was transferred from research facility or undergoing permitted research 

during rehabilitation – Research activity may extend the frequency and intensity of 

handling time and therefore could increase the risk of altering behavior or increasing the 
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chance of exposure to facility pathogens or chemicals (e.g., anesthetic agents, metabolic 

agents, etc). These animals will be considered “Conditionally Releasable” or “Nonreleasable.” 

4.4 Developmental Assessment of Pinnipeds 

In order to be deemed "Releasable," a young pinniped should be able to feed itself and have adequate 

body condition to survive readjustment to the wild. Generally, pups are to be held in rehabilitation 

centers for roughly the normal duration of lactation. Because maternal dependence may vary greatly 

in some species, it is recommended that the straight length and weight of each pinniped pup be taken 

at admission and again when evaluating the animal for release to aid in the assessment of the animal’s 

body condition. Such measurements may be compared to known weaning lengths and weights of 

appropriate wild pinniped species or to data from successfully rehabilitated and released stranded 

pups (see Appendix I for species specific developmental stages and pupping information). The risk 

of altered behavior can be related to both the length of treatment and the age of the animal at the time 

of stranding. Pups stranded as maternally dependent neonates and animals spending an extended time 

in rehabilitation being at highest risk. Special care should be taken with these species especially if 

rehabilitating very young pups and should be considered “Conditionally Releasable”. 

Reproductive status in and of itself does not impact release candidacy of a pinniped unless a female 

strands with her pup or gives birth during rehabilitation. Such females and their offspring are 

“Conditionally Releasable” and are to be discussed with NMFS or FWS. The natural history of the 

pinniped species involved and factors related to maternal relationship may impact the timing and 

conditions of release for mother or pup. For instance, a pup that has not reached weaning weight may 

be releasable with its mother, but not alone. A healthy mother may be kept in rehabilitation to assist 

its sick or injured pup; however, this should be weighed against the risk of habituation that could 

minimize the chance of a successful release. Female pinnipeds in estrus or late pregnancy are 

releasable unless the attending veterinarian believes that the health history of the animal warrants 

extra precautions to minimize stress during its return to the wild. Such animals are “Conditionally 

Releasable” due to health concerns and are to be discussed with NMFS or FWS. 

Pinnipeds that are in molt are “Conditionally Releasable” and these cases should be discussed with 

NMFS. Because behavior and physiology change during a molt, factors related to the pinnipeds 

health history, age, reproductive status, and other relevant parameters should be considered in order to 

determine if release is preferable to holding the animal until molting is completed. 
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4.5 Behavioral Assessment of Pinnipeds 

The limitations imposed by the captive environment of rehabilitation may preclude a detailed 

behavioral assessment where behavior of the captive animal may differ from that displayed in the 

wild. Also, there lacks a set of behavioral and functional tests that relate to behavior in the wild and 

there are limitations on the complete knowledge of “normal” behavioral parameters of each species. 

Behavioral clearance is thus founded on basic criteria necessary for survival of the animal in the wild. 

The behavioral evaluation often overlaps with the medical evaluation as abnormal behavior may 

indicate an underlying illness. Biologists and animal care supervisors with expertise in pinniped 

behavior and the attending veterinarian should jointly assess the behavior of the animal. 

To achieve behavioral clearance, a pinniped should breathe normally and demonstrate effective 

swimming, diving, and locomotion on land (if appropriate for its species). The animal should not 

display aberrant behavior or auditory or visual dysfunction that may compromise its survival in the 

wild or suggest an underlying disease of concern to wild marine mammals (i.e., reportable disease). 

Behavioral clearance also includes confirmation that the animal can respond to, and is able to capture 

and consume, live prey. 

4.5.1 Breathing, Swimming, Diving, and Locomotion on Land 

Evaluation of respiration is done to determine that the pinniped does not exhibit abnormal breathing 

patterns or labored breathing during exertion. Evaluation of swimming, diving, and locomotion on 

land is done to confirm that the pinniped moves effectively and does not exhibit abnormalities such as 

listing to one side, decreased capacity to submerge, asymmetrical motor patterns, etc. Pinnipeds that 

display abnormalities of breathing, swimming, diving, or locomotion on land are deemed 

"Conditionally Releasable" or "Non-Releasable," depending on the nature and degree of their 

dysfunction. 

4.5.2 Aberrant Behavior 

Behavioral clearance of the pinniped includes confirmation that the animal does not exhibit aberrant 

behavior that may compromise survival in the wild or suggest an underlying disease of concern to 

wild marine mammals. Examples of aberrant behavior include, but are not limited to, regurgitation, 

head pressing, postural abnormalities such as repetitive arching or tucking, head swaying, stereotypic 

or idiosyncratic pacing, decreased or unusual range of motion, and abnormalities of breathing, 

swimming, diving, and locomotion on land as previously discussed. Other examples include 
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attraction to or desensitization to the presence of humans such as in the case of pups imprinting on 

humans. Pinnipeds displaying aberrant behavior are deemed "Conditionally Releasable" or "NonReleasable" depending on the nature and degree of the behavior. 

4.5.3 Auditory and Visual Function 

Behavioral clearance of the pinniped includes evaluation of auditory and visual function. Auditory 

dysfunction may be a reflection of active disease, permanent injury, or degenerative changes 

associated with aging. Evaluators may suspect that a pinniped has compromised auditory function if 

it responds minimally to loud noises created above or below water. Pinnipeds that have visual 

dysfunction may show difficulty locating prey items, tendency to collide with boundaries of their 

enclosure, or difficulty maneuvering about objects placed in their path. Discoloration, swelling, 

abnormal shape, position, or appearance of the eye or eyelids may suggest visual dysfunction. 

Pinnipeds with auditory or visual dysfunction should be deemed "Conditionally Releasable" or "NonReleasable" depending on the degree and nature of their condition. 

4.5.4 Prey Capture 

Rehabilitated pinnipeds should demonstrate the ability to chase, capture, and consume live prey prior 

to their release. Prey items found in the animal’s natural environment should be used whenever 

possible. If natural prey items are not available, evaluators may utilize other prey species. Evaluation 

of the pinniped includes assessment of each component of feeding behavior including the ability to 

chase prey, to actually capture prey, and to consume prey without assistance from humans. Pinnipeds 

that display ineffective prey capture and consumption are deemed "Conditionally Releasable” or 

“Non-releasable." If logistical issues preclude evaluation of prey capture and consumption or there is 

a question about the quality of live prey, NMFS or FWS should be consulted. 

Rehabilitated pinnipeds that have been in captivity longer than one year and young pinnipeds having 

little or no previous foraging experience in the wild require particularly careful assessment of feeding 

behavior. Repeated feeding trials using live prey with concurrent assessment of the animal’s ability 

to maintain good body condition are helpful in thoroughly evaluating such animals.

4.6 Medical Assessment of Pinnipeds 

The medical assessment includes information related to any diagnostic testing, treatment, and 

response to treatment. The attending veterinarian should perform a hands-on-physical examination 

upon admission and prior to the release determination. The attending veterinarian should review the 
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animal’s complete history including all stranding information and diagnostic testing (i.e., required by 

NMFS and any additional data), and medical and husbandry records (including food consumption and 

weight and length progression). The primary goal of testing required by NMFS or FWS is to 

safeguard the health of wild marine mammal populations. This is achieved by testing for diseases 

that pose a significant morbidity or mortality risk to wild populations (i.e., reportable diseases). 

Those that are zoonotic or public health and safety concern require immediate NMFS notification to 

assure proper protocols are put into place. Additional testing will be required if the animal was part 

of an official UME. NMFS may request testing for other emerging diseases as part of a surveillance 

program to identify potential epidemics of concern and to monitor changes in disease status that may 

have occurred due to rehabilitation practices. The directive for the pre-release health screen will come 

from the NMFS Regional Stranding Coordinator through the MMHSRP. Appendix E lists diseases of 

concern for pinnipeds. 

A complete health screen should be completed upon admission and just prior to release including 

basic blood collection for a CBC, chemistry profile (including BUN and creatinine, enzymes and 

electrolytes), serology, microbial and fungal culture (i.e., nasal, rectal, ocular, and lesions), cytology, 

urinalysis, and fecal exam. If the animal is female and at reproductive age, it is advisable that 

pregnancy is ruled out prior to prescribing potentially fetal toxic medication. Serum (3ml/each) 

should be banked at the time of admission and just prior to release for retrospective studies. Cessation 

of antibiotics should occur two weeks prior to release examination to assure that the animals is no 

longer dependent on the medication and that the drug has cleared based on the pharmacokinetics and 

requirements made by the veterinary community and the Food and Drug Administration. Some 

antibiotics clear the body quickly and require shorter withdrawal time; therefore, when this 

recommendation cannot be met seek advice from NMFS. The attending veterinarian should 

provide written notification to the NMFS Regional Stranding Coordinator that a pre-release 

health screen of the pinniped has been performed two weeks prior to release and will be 

conducted within 72 hours of release as a final check. The two week notification must also 

include the final release plan. The final assessment at the 72 hour mark can be emailed just 

prior to the release or immediately following the release as prescribed by the NMFS Regional 

Stranding Coordinator. The required documentation and signed release determination 

recommendation will be part of the administrative record along with the signed (by the NMFS 

Regional Administrator) letter of concurrence approval for release. 
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It is of extreme importance that the pinniped be monitored closely for disease throughout its 

rehabilitation. Regardless of the stranding etiology, handling and care can cause significant stress 

increasing susceptibility to disease. If not properly managed, rehabilitation facilities provide an 

environment where genetically altered or novel pathogens not typically encountered in the wild can 

easily be transmitted from animal to animal. This scenario can be problematic when an animal is 

exposed and becomes a carrier of that pathogen to a naïve wild population if released. Introduction of 

pathogens from rehabilitation centers to the wild is a significant concern as diseases with serious 

epizootic potential have been detected (Measures 2004, Moore et. al., 2007). Infectious agents may 

become more pathogenic as they pass through new individuals and naïve species or genetically 

altered from indiscriminant use of antibiotics. 

The attending veterinarian is urged to utilize the full spectrum of diagnostic modalities available for 

health assessment of the pinniped. In addition to basic blood work, serology, microbial culture, 

cytology, urinalysis, and fecal exam, advanced techniques for pathogen detection such as PCR and 

toxicology analyses are available. A number of diagnostic imaging techniques including radiology, 

CAT scans, and MRI may be used as well as bronchoscopy and laparoscopy. The pinniped literature 

has expanded to include numerous references on the performance and interpretation of diagnostic 

tests. 

Both agencies may request testing for other emerging diseases as part of a surveillance program to 

identify potential epidemics of concern and identify health trends. Additional testing will be required 

if the animal was part of an official UME. Specific testing requirements (i.e., pre-release health 

screen) will come from the NMFS Regional Stranding Coordinator through the MMHSRP and 

follows the term and responsibilities stated in the NMFS Stranding Agreement. 

4.7 Release Site Selection for Pinnipeds 

The release of a rehabilitated pinniped should be planned to maximize its chances for survival. The 

release should be timed and staged to increase its likelihood of foraging success and acceptance by 

conspecifics. Factors including its species, age, reproductive status, previous home range, social unit, 

and migratory patterns should be considered. Weather conditions at the release site and other 

environmental factors impacting the habitat and food availability should also be evaluated. 

 The rehabilitated pinniped is to be released into its home range, genetic stock, and social unit 

whenever possible. Return of the animal to its home range is preferable as the reacclimating pinniped 

would presumably have familiarity with available resources, potential predators, environmental 
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features, and social relationships. In many cases, this can be accomplished by releasing the pinniped 

at its stranding site through a simple hard-release process (i.e., the animal is released directly after 

transport to the release site without acclimation through holding in a temporary enclosure at the site). 

For wide ranging species, such as hooded and ringed seals, the release site selection is considered on 

a case-by-case basis. Consultation with NMFS is required for these cases. If the range of 

conspecifics is distant form the original stranding site, rehabilitators may consider various options 

depending on the natural history of the species and the temporal relationship of release to seasonal 

distribution. The pinniped may be released to migrate on its own or with conspecifics still in the 

vicinity. Alternatively, the pinniped may be held in captivity until conspecifics return or it may be 

transported to the location of its migrated cohorts. The risks of extended time for the pinniped in 

captivity, logistics of transport to a migration site, and costs associated with the extended stay are 

examples of factors to be considered. As explained later in this section, movement of pinnipeds 

recovering from infectious disease to other sites should be carefully considered regarding disease risk 

to wild pinnipeds. 

When information on the animal’s ranging patterns or social unit prior to stranding is not known, or 

when a pinniped strands outside of the previously known range of its species, NMFS is to be 

consulted regarding an appropriate release strategy. For pinniped species that have vast territorial 

ranges, such as those that naturally traverse the length of the North American continent, knowledge of 

the animal’s specific ranging patterns previous to stranding may not be necessary. Such pinnipeds 

may be released in the general vicinity of their stranding site or anywhere within the vast range 

inhabited by that species with the following important exception (see below). 

When a pinniped has recovered from an infectious disease, it may be preferable to release the animal 

near its original stranding site in order to minimize disease risks to wild pinnipeds. For example, 

even if the entire population of a far-ranging pinniped species has been exposed to a particular 

infectious agent, changes in the virulence of the pathogen may initially occur at distinct geographical 

sites. A seal exposed to a particularly virulent strain of pathogen in the far Northeast may pose a 

health risk to pinnipeds in the Mid-Atlantic that have not yet encountered that particular strain of 

virus. Additionally, the clinical signs of many infectious diseases mimic each other. As 

rehabilitation centers cannot always perform definitive diagnostic tests for all viral agents, moving 

rehabilitated pinnipeds from the general region of their stranding to distant locations for release may 

pose some risk to wild marine mammals. NMFS is to be consulted regarding the preferred release 

site when pinnipeds recovering from an infectious disease cannot be released near their original 
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stranding site. Another important consideration is the location of the rehabilitation facility to the 

normal habitat range for the species, e.g., the rehabilitation of an ice seal in the Caribbean. The 

decision to release in the normal habitat range would need to be thoroughly discussed with NMFS. 

It is important to ensure that conditions at the release site do not pose any obvious immediate threat to 

the released animal, such as areas where resources and habitat is severely depleted or degraded. If 

evidence exists of a substantial decline in resources or habitat quality such as massive fish kills, 

significant declines in commercial and/or recreational fish landings, red tides, etc., it may not be 

appropriate to release the pinniped until conditions at the release site improve or a different release 

site is found. Also, release in areas of dense public use and/or high commercial and recreational 

fishing activity should be avoided. 

4.8 Identification of Rehabilitated Pinnipeds Prior to Release 

NMFS and FWS have determined that all pinnipeds must be flipper tagged for identification prior to 

release to the wild. Tags and placement instructions are to be obtained from NMFS or FWS and/or 

USGS (for walrus) as appropriate for the pinniped species (see Appendix H for contact information. 

Although resightings of flipper-tagged individuals may provide some information regarding the 

relative success of a rehabilitation effort, flipper tags are not reliable for long-term monitoring. They 

may be difficult to read from a distance and may become damaged or lost. Other methods for 

identification such as freeze-branding, glue tags, etc. may be used in addition to flipper tags (Geraci 

and Lounsbury 2005). 

4.9 Post-Release Monitoring of Pinnipeds 

Post-release monitoring of pinnipeds provides essential information for the development and 

refinement of marine mammal rehabilitation and release practices. Post-release monitoring methods 

may include visual observations of tagged or freeze-branded pinnipeds from land, sea, or air, as well 

as radio or satellite-linked monitoring. Radio and satellite-linked monitoring programs are highly 

desirable as they provide a wealth of information regarding the activities and fates of released 

animals. NMFS or FWS may require and coordinate post-release monitoring plans for “Conditionally 

Releasable” pinnipeds. Additionally, rehabilitation centers may voluntarily provide post-release 

monitoring plans for routinely released pinnipeds. When such monitoring will be performed 

voluntarily, the rehabilitation center is required to inform NMFS or FWS of the intent to implement 

post-release monitoring when seeking authorization for release of the pinniped. 
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The first month after release of the pinniped is a particularly critical period during which it will 

become evident whether the animal is thriving, including capturing sufficient prey and being accepted 

by conspecifics. It is recommended that monitoring continue on a regular basis via field observations, 

radio, or satellite-linked monitoring for up to one full year and such funding resources as the Prescott 

Grant Program can assist with the financial burden of such endeavors. NMFS may request these data 

in order to make future revisions to pinniped rehabilitation and release guidelines. In order to 

compare individual cases, standardization of data collection protocols for monitoring released 

pinnipeds may be helpful, and this should include the length of the tracking time, the type of tracking 

equipment, and assessment of outcome. Formal study of monitoring data and its dissemination to the 

stranding network can aid in the assessment of pinniped rehabilitation and release programs. 

Release plans should include contingency plans for recovering the released pinniped, should 

monitoring indicate its failure to thrive, including options for treatment, permanent care, or 

euthanasia. In addition, NMFS will request such contingency plans for “Conditionally Releasable” 

pinnipeds, depending on the circumstances. 
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5. Guidelines for Release of Rehabilitated Manatees 

5.1 Introduction 

West Indian manatees (Trichechus manatus) are found throughout the Caribbean basin. In the United 

States, the Florida subspecies (Trichechus manatus latirostris) is commonly found in southeastern 

coastal waters, with Florida at the core of its range. The Antillean subspecies (Trichechus manatus 

manatus) is found outside of Florida throughout the Caribbean basin (including Puerto Rico and 

possibly Texas). While most reports of distressed manatees occur in Florida, manatees have been 

rescued throughout the region. The focus of manatee rescue and release activities is to promote the 

conservation of wild manatee populations. 

Reports of distressed manatees include animals compromised by human activities and natural causes. 

Human causes of distress include collisions with watercraft, entrapment in structures, entanglement in 

and ingestion of fishing gear and debris, and other sources. Natural causes of distress include 

exposure to cold and brevetoxins, mother/calf separation, seasonal disorientation, etc. All rescuerelated communications and the day to day decision making process in the field are generally handled 

by the local field Stations of the Florida Fish and Wildlife Conservation Commission (FWC) in 

conjunction with report from the public utilizing the FWC hotline (1-888-404-FWCC). All activities 

related to the verification of a report of a manatee in trouble, subsequent rescue, and transport to 

rehabilitation facilities are communicated through the FWC Field Stations, according to established 

protocols. The FWS Jacksonville Field Office coordinates the manatee rescue, rehabilitation, and 

release program to assist these animals. The FWS Jacksonville Field Office conducts this program 

according to the provisions of an ESA/MMPA marine mammal enhancement permit issued by the 

FWS DMA. The permit authorizes “take” activities for an unspecified number of manatees for the 

purpose of enhancing its survival and recovery, consistent with the FWS manatee recovery plan 

developed pursuant to the ESA. 

The FWS Jacksonville Field Office coordinates a network of individuals, facilities, and agencies 

authorized as subpermittees under their enhancement permit and through LOAs issued under section 

109(h) and section 112(c) of the MMPA [16 U.S.C. 1379(h) and 16 U.S.C. 1382(c)] to authorize 

activities related to the rescue (including temporary capture, possession, transport, and transfer), 

rehabilitation, and post-release monitoring of manatees. 
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The following guidelines were first developed by program participants in 1991 and subsequently 

revised in 2001. They are based on more than twenty years of program history and include the 

experiences, advice, and expertise of resource managers, field biologists, veterinarians, behavioral 

experts, animal keepers, and other dedicated individuals. The guidelines are to be used by authorized 

participants to guide the return of rehabilitated manatees to the wild. 

5.2 Overview of Release Categories for Manatees 

Manatees undergoing rehabilitation are evaluated by program participants and placed into one of four 

Release Categories: 

1. “RELEASABLE”: Manatees that have been successfully treated, are of an appropriate size, 

demonstrate appropriate behaviors, have the skills necessary to thrive in the wild, and do not 

pose a threat to wild populations will be considered releasable. Additionally, distressed 

manatees that are assisted in the wild and then released on-site are characterized as 

“Releasable”. These include fit (healthy, non-injured) manatees superficially entangled in 

fishing gear, animals isolated by high water or detained by structures (such as water control 

structures, sheet pile walls, booms, and other barriers), seasonally disoriented animals, and 

others. “Seasonally disoriented” manatees include otherwise fit animals that fail to migrate to 

appropriate winter habitats during the periods of cold weather. These animals are typically 

relocated to warm water sites within their region of origin. 

2. “CONDITIONALLY RELEASABLE”: Manatees with a condition and/or circumstances 

that present a question regarding the success of release or ability to thrive in the wild but 

likely not pose a threat to wild populations will be considered conditionally releasable. 

Animals described as “Conditionally Releasable” typically include medically-cleared, 

captive-reared animals and older, long term-captives. The status of animals considered to be 

“Conditionally Releasable” may change to “Releasable” if their condition or circumstances 

improve or to “Conditionally Non-releasable” if their condition or circumstances deteriorate. 

3. “CONDITIONALLY NON-RELEASABLE”: Manatees that cannot be released because 

their condition and/or circumstances threaten the well-being of the animal and/or may pose a 

threat to the wild population will be considered conditionally non-releasable. The status of 

animals considered to be “Conditionally Non-releasable” may change to “Releasable” or 

“Conditionally Releasable” if their condition or circumstances improve over time. This 
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category may include individuals with permanently debilitating medical conditions. Because 

manatees are closely monitored post release (i.e., their normal habitat range is coastal and 

thus easier to monitor post release) and data have shown that they can survive and thrive post 

release even after many years in captivity, this category has been added. 

4. “NON-RELEASABLE”: The FWS will review, on a case-by-case basis, requests to 

establish the non-releasability of certain captive-held manatees. Manatees deemed nonreleasable will be medically characterized by a disease process that proves to be a significant 

risk to the wild population or by significant physical injuries (such as loss of paddle or 

significant spinal trauma) that would preclude the ability of an animal to thrive in the wild. 

Petitions to establish non-releasability of individual manatees will be reviewed by an 

independent panel which will make their recommendations to the FWS. The FWS will 

consider the request and recommendation and will then determine the status of the animal. 

Should an animal be deemed non-releasable by the FWS, the receiving facility will need to 

meet the requirements to receive an enhancement permit in accordance with section 104 

(c)(4) of the MMPA (16 U.S.C. 1374(c)(4)), section 10(a) of the ESA (16 U.S.C. 153(a)) and 

the FWS issuance criteria at 50 CRF 17.22. 

5.3 Historical Assessment of Manatees 

Efforts are made to maintain complete, detailed records that document rescued manatees from the 

time of rescue to their eventual disposition. These records generally include information describing 

the rescue, circumstances surrounding the stranding (e.g., red tide, cold weather, etc.), treatment(s), 

captive care, and resolution of the case (i.e., death, euthanasia, or release). In the case of previously 

known wild individuals, these records can include documentation of behavioral and reproductive 

patterns, migratory habits, and site fidelity. For all released animals, these records should also 

include all post-release monitoring information. 

These records guide the treatment of individual stranded manatees and provide an evaluative tool that 

allows program managers and participants to assess and improve methods and procedures to better 

ensure success. As an example, in the case of red tide-related strandings, records detail the rescue of 

a manatee(s), noting the stranding site in the context of a red tide event, the presentation of the animal 

(beached, convulsing, etc.), any behaviors noted during transport, appropriate neurologic treatment, 

post treatment observations, and eventual release. Release plans for the animal should require 

information characterizing the status of red tide within the planned release area. Such detailed 
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documentation has helped with efforts to develop effective rescue, rehabilitation, and release methods 

for red tide stranded animals. 

5.4 Developmental Assessment of Manatees 

“Releasable” animals must be nutritionally independent (weaned and off of supplemental nutritional 

support), greater than 200 cm in total length and more than 600 pounds in weight. There should be no 

concerns regarding the animal’s length of time in captivity, relative to its age. On occasion, smaller 

suckling calves are released with their dam to ensure that the dam’s wild experience is passed on to 

her calf. Based on observations of cow/calf bonding behavior, this will help to improve the calf’s 

wild skills and ability to survive in the wild. 

“Conditionally Releasable” manatees should demonstrate nutritional independence, especially in the 

case of older calves planned for release. Recently weaned juveniles are also considered as release 

candidates. In both instances, animals should meet “Releasable” criteria for length and weight. 

Manatees that have spent lengthy periods of time in captivity (relative to their age) also fall into this 

category. Concern has been expressed that older, long-term captives may have a diminished ability to 

thrive in the wild (at the extreme are animals that have been in captivity for more than 50 years). 

While concern for these older animals may be well-placed, it is difficult to know at what age (if any) 

these animals’ condition and lack of wild skills will compromise the success of their release. As 

such, older animals are considered on a case-by-case basis for release. The release of older manatees 

is being conducted in the context of a research program that will yield data to help ensure success for 

subsequently released individuals meeting similar criteria. 

“Conditionally Non-releasable” manatees include animals that are not nutritionally independent, do 

not meet the length and weight criteria for “Releasable” animals, and/or lack the wild skills that are 

essential for a successful release. 

“Non-releasable” manatees will be reviewed by the FWS on a case-by-case basis. 

5.5 Behavioral Assessment of Manatees 

“Releasable” manatees must exhibit normal behaviors while in captivity and are, therefore, expected 

to be able to meet behavioral challenges when in the wild. Normal behaviors include typical 

breathing, swimming, diving, and foraging/drinking patterns. Foraging behaviors include the ability 

to feed in salt, brackish, and fresh water environments without becoming dehydrated. Manatees must 
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also demonstrate an ability to feed on natural vegetation located at various levels in the water column. 

Historically, captive manatees have been fed at the water surface. Naïve animals fed in this fashion 

have had difficulties finding food on the bottom after release. Current feeding practices include 

feeding at the bottom and top of the water column. 

While abnormal behaviors in manatees have not been defined, animals that exhibit atypical behaviors 

(as determined by FWS and its advisors) while in captivity will be considered for release on a caseby-case basis. Behaviors that elicit concerns include stereotypic behavioral displays, adaptability or 

sensitivity to change (including going off feed, shutting down, etc.), and perceived affinities for 

humans and human activities while in captivity. These affinities should not be confused with the 

manatee’s innate ability to explore their captive environment, including humans, especially in the 

absence of other engaging stimuli. Efforts should be made to de-condition or extinguish these 

behaviors before release. 

5.6 Medical Assessment of Manatees 

Prior to release, release candidates must be examined by a veterinarian experienced in manatee 

medicine. Examinations should include a review of the animal’s complete history, a hands-on 

physical examination, and diagnostic testing. The exam should include blood work, including CBC 

and serum chemistries. Serological and bacteriological assessments should be conducted when 

deemed necessary by the attending veterinarian. Results of analyses should be consistent with known 

values for animals of similar age, size, and sex and consistent with historical values for that specific 

animal. A “medically cleared” manatee will be free of medical problems, not limited in its ability to 

thrive in the wild, and will not pose a threat to wild populations. 

Manatees that have unresolved injuries, compromising physical conditions (malnutrition, 

dehydration, etc.), active/infectious disease processes, injuries that significantly affect mobility and 

range of motion (e.g., the loss of a paddle, failure to adapt appropriate buoyancy control, etc.) and 

other debilitating conditions are considered to be “Conditionally Non-releasable”. In the event that 

these concerns are resolved, these animals may be categorized as “Releasable” or “Conditionally 

Releasable”. 
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5.7 Decision Tree for Release Categories - Manatees 

The following is a list of criteria used to help determine the release status of captive manatees. Please 

note that an animal’s status may change as various criteria are met. (These criteria generally apply to 

all species/subspecies of manatees unless otherwise indicated.) 

5.7.1 RELEASABLE 

Developmental Stage/Life History 

a) Nutritionally independent. 

b) For Florida manatees, length must be >200 cm and weight >600 lbs (unless released with 

dam). 

c) No concerns about length of time in captivity relative to age. 

Behavioral Assessment

a) Must exhibit normal behaviors, including typical breathing, swimming, and diving patterns 

while in captivity. 

b) Must be able to eat natural vegetation and adapt to salt, brackish, and fresh water regimes. 

c) Must demonstrate ability to feed on natural vegetation at various levels in water column. 

Medical Assessment

a) No active, demonstrable medical problems. 

b) Medically cleared based on examination by a veterinarian experienced in manatee medicine. 

c) Poses no threat to wild populations. 

Pre-release Requirements

a) The animal must be individually recognizable. 

i. All identifiable markings should be completely documented with sketches and 

photographs. 

ii. In the absence of individually identifiable markings, the animal should be freeze 

branded. The brands should be sketched and photographed. 

iii. All released manatees should be PIT-tagged and information recorded and logged. 

b) Blood and/or tissue samples must be taken for serum banking and genetics. 
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c) Ultrasound measurements of blubber layers must be taken as an initial indicator of health 

status. 

Release Logistics (a release plan should be prepared for each released animal) 

a) Telemetry should be considered when appropriate, subject to approval by FWS. 

b) Animals should be released in close proximity to their point of origin, when appropriate (in 

the case of previously known animals, suitable sites may be selected within the animal’s 

home range). 

c) Release sites should be free of harmful algal blooms and other compromising factors. 

d) For captive-reared, naïve animals in Florida, release sites should include natural warm water 

sites within the animal’s home range or that of the parent. Such releases should occur during 

the winter, thereby improving possibilities for bonding to the site and building associations 

with cohorts. 

5.7.2 CONDITIONALLY RELEASABLE 

Developmental Stage/Life History - Developmental considerations include animals that may be 

characterized by one or more of the following conditions: 

a) Partial nutritional independence. 

b) For Florida manatees, less than 200 cm in length and/or 600 lbs in weight. 

c) Social dependence. 

d) Recent weaning (stranded as a neonate, captive weaned, etc.). 

e) Extended period of time (relative to age) in captivity. 

Behavioral Assessment

a) Exhibits abnormal behavior(s) in captivity. 

b) Unable to eat natural vegetation and adapt to salt, brackish, and fresh water regimes. 

c) Unable to feed on natural vegetation at various levels in water column. 

Medical Assessment: Animals with the following conditions may be considered for release: 

a) Physical impairment (may include animals with damage to or loss of appendages, animals 

with impaired range of motion, etc.) 

b) Reproductive condition (may include pregnant females, lactating females with calves, etc.) 
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Pre-release Requirements

a) The animal must be individually recognizable. 

i. All identifiable markings should be completely documented with sketches and 

photographs. 

ii. In the absence of individually identifiable markings, the animal should be freeze 

branded. The brands should be sketched and photographed. 

iii. All released manatees should be PIT-tagged and information recorded and logged. 

b) Blood and/or tissue samples must be taken for serum banking and genetics. 

c) Ultrasound measurements of blubber layers must be taken as an initial indicator of health 

status. 

Release Logistics

a) Requires radio-tagging and intensive monitoring efforts following guidelines developed by 

FWS and its advisors (including veterinarians, animal behavior specialists, and researchers). 

5.7.3 CONDITIONALLY NON-RELEASABLE 

Developmental Stage/Life History - Developmental considerations include animals that may be 

characterized by one or more of the following conditions: 

a) Nutritionally dependent. 

b) For Florida manatees, less than 200 cm in length and/or 600 lbs in weight. 

c) Extreme concerns about length of time in captivity relative to age. 

Behavioral Assessment

a) Exhibits abnormal behavior(s). 

b) Unable to eat natural vegetation and adapt to salt, brackish, and fresh water regimes. 

c) Unable to feed on natural vegetation at various levels in water column. 

Medical Assessment

a) Not medically cleared (animals with active/infectious diseases, permanent, demonstrable 

physically debilitating injuries, and/or other concerns). 

b) Poses a threat to wild populations. 
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5.7.4 NON-RELEASEABLE 

a) Animals deemed permanently non-releasable will be: 

i. Permanently captive 

ii. Euthanized, as deemed necessary, to prevent pain and suffering or in cases with an 

inevitable outcome. 

If FWS has determined that a manatee is permanently non-releasable, the holding facility 

may request a permit for permanent placement of the animal as long as the facility meets the 

requirements under section 104(c)(3) or (c)(4) of the MMPA and section 10 of the ESA. 

b) Inbred animals: There are currently two inbred manatees in the U.S. captive manatee 

population. At the present time, these animals are considered to be conditionally nonreleasable due to concerns regarding immunological compromise. Other concerns include 

observed problems with inbreeding, as seen in the European captive manatee population, 

which includes high infant mortality and breeding suppression. Given these concerns and 

questions about the effects of the release of inbred animals into the wild population, these two 

animals can not be released at this time and are presently considered conditionally nonreleasable. 

c) Pre-Act animals: The U.S. captive manatee population currently includes four Florida 

manatees brought into captivity prior to the adoption of Federal prohibitions preventing the 

display of endangered marine mammals. The care and disposition of these “Pre-Act” animals 

are the responsibility of their respective owners. 

5.8 Pre-release Requirements for Manatees 

Prior to release, all animals must be individually recognizable. While many animals are either 

naturally marked or have scars from encounters with boat propellers, other animals have no markings 

and should be freeze branded with a unique number/letter combination (the selection of the sequential 

number/letter combination must be made beforehand in consultation with FWS). All markings 

(including freeze brands) should be done well in advance of release, if possible, and all markings 

should be sketched and photographed. PIT tags (one on either side of the shoulders, cranial to each 

scapula) should also be implanted. Ultrasound measurements of blubber layers must be taken prior to 

release as a baseline indicator of the animal’s body condition. Blood and/or tissue samples should 

also be taken prior to release for serum banking and genetics. 
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5.9 Release and Post-release Logistics for Manatees 

If at all possible, animals should be released in close proximity to the site where originally rescued. 

For captive-reared, Florida manatees with no wild experience, these animals should generally be 

released within their region of genetic origin and into natural warm-water areas during the winter to 

encourage winter site fidelity and familiarity with local conditions and association with wild 

manatees. When appropriate, telemetry may occur, pursuant to approval from FWS. (Current 

tagging methodologies make it difficult to radio tag and belt manatees less than 220 cm in total 

length.) In the case of rehabilitated, wild born adults, many of these animals can be released back 

into areas where researchers actively track wild manatees and can be monitored as part of these 

projects. 

Post-release monitoring is required for all conditionally releasable animals. Such monitoring includes 

equipping animals with transmitters (satellite, VHF, and/or sonic, as appropriate) for both remote and 

on-site monitoring, On-site monitoring should include visual observations of the animal once or 

twice a week; protocols vary between higher and lower risk candidates. At a minimum, biomedical 

assessments should be conducted within the first three months after release, six months after release, 

and twelve months after release. If there is any question about the animal’s health based on field or 

remote observations, assessments should occur more frequently. If the animal’s well-being has been 

compromised as determined by these assessments, the animal should be returned to captivity. 

Biomedical monitoring includes an examination of overall body condition, length and other 

morphometrics that include girths, weight, blubber thickness, collection of blood, fecal, urine, milk, 

semen, and tissues samples when possible. Results of analyses should be consistent with known 

values for animals of similar age, size, and sex and consistent with historical values for that specific 

animal. While there is no agreed upon definition of success, program participants generally agree that 

if an animal has thrived in the wild (and met foraging and fresh water needs) for at least a year, if it 

has demonstrated an ability to successfully winter at a warm water site (Florida manatees), and if it 

has contributed to the production of offspring, then it is considered a successful release. 

Pre-release conditioning may be required for conditionally releasable animals. Such conditioning 

may include exposing manatees to natural forage positioned at the surface and on the bottom of their 

tank. Natural forage includes a variety of vegetative types found within the animal’s range and may 

also include palatable exotics such as Hydrilla. If an animal is to be released into water that differs 

from the type of water in their tank of origin, the animal should be acclimated to the type of water 

best suited to the release environment to minimize post-release stress, especially in the case of naïve 
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animals. Conditioning may also include minimizing exposure to humans to reduce or eliminate any 

affinity the animal may have or may potentially develop toward humans and human activity. 

Trained/learned behaviors must be extinguished to the greatest extent possible prior to release. 

In special cases, “soft release” methodologies should be considered as a means to enhance 

survivorship in the wild. “Soft releases” typically rely upon temporary holding facilities established 

within the release area. Manatee(s) are kept in these facilities where they are maintained and 

observed for a period of at least several weeks. This temporary adaptation period allows for 

acclimation to waters at the release site, introduction to in situ forage, close observation of behaviors, 

and ease in capture/handling for biomedical assessments prior to release. Supplemented forage can 

be reduced during the containment period. At release, the “soft release” concept initially encourages 

brief forays away from the enclosure and allows for the individual to return to the now familiar 

holding facility. Further reduction in supplemental feeding will promote greater use and exploration 

of surrounding habitats. Use of this methodology is to be considered where individual cases warrant 

additional release scrutiny and release locations allow for its implementation. 

5.10 Manatee Rescue, Rehabilitation, and Rescue Program 

Reporting/Requesting Requirements 

The FWS uses an electronic database that requires program participants to report events within 24 

hours of occurrence. Release requests should be received and requested electronically 30 days prior 

to the release. The Reporting Requirements are listed in Appendix C. 
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6. Guidelines for Release of Rehabilitated Sea Otters 

6.1 Introduction 

Sea otters are found in near shore waters of the North Pacific. Several subspecies and stocks have 

been identified in California, Washington, Alaska, Canada, and Russia. Sea otters may strand for a 

variety of reasons including trauma, disease, and the inability to forage. Guidelines for the release of 

rehabilitated sea otters are intended to address the welfare of these animals and any impacts the 

rehabilitated animals may have on wild otter populations. 

Like many other marine mammals, stranded sea otters are often reported on beaches frequented by 

humans. In some cases, humans intercede and otherwise healthy pups are removed from the wild. 

The sea otter’s small size makes it relatively easy to transport. However, there are currently few 

facilities capable of meeting the requirements for successful rehabilitation. These guidelines are 

intended to be used by facilities authorized to rehabilitate marine mammals under the MMPA and 

ESA, if applicable, and that are actively involved in the rehabilitation of sea otters for subsequent 

return to the wild. Questions regarding disposition and release approval of stranded sea otters must 

be directed to the appropriate FWS specialist as identified in Appendix H. 

6.2 Developmental Assessment of Sea Otter Pups 

Sea otter pups are generally dependent on their mothers for the first 6 to 12 months of life. Newborn 

pups are readily distinguished by their natal pelage, small size (generally less than 6 lbs), and inability 

to care for themselves. Pups prematurely separated from their mothers or found stranded on a beach 

shortly after weaning are generally less than 20 lbs in weight and typically lack foraging skills 

necessary for survival. 

Successful rehabilitation of stranded sea otter pups for release to the wild requires a significant 

commitment of time and resources. Facilities that receive a stranded pup and are unable to rear the 

pup for possible release to the wild must immediately contact the FWS (as identified in Appendix H) 

to determine the disposition of the animal. 

Rehabilitated sea otter pups that are at least 6 months of age, weigh at least 20 lbs, demonstrate 

adequate foraging, grooming, and social skills may be released to the wild. Rehabilitated sea otter 

pups must be monitored closely post-release to determine if their transition to the wild is successful 

(see post-release monitoring below). 
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6.3 Behavioral Assessment of Sea Otters 

Certain behaviors are necessary for survival of rehabilitated sea otters. In addition, aberrant 

behaviors may preclude release to the wild. Rehabilitated sea otters may be released to the wild if the 

following behavioral criteria are met in the opinion of rehabilitation personnel familiar with normal 

sea otter behavior: 

1. The rehabilitated sea otter must demonstrate the ability and willingness to forage and capture 

live prey. This includes the use of tools such as rocks used to pound shelled prey; 

2. The rehabilitated sea otter must demonstrate basic survival skills and activities including 

active foraging, pelage management, diving, and resting; 

3. The rehabilitated sea otter must demonstrate “normal” social skills including interest in other 

sea otters and should exhibit a wariness of humans and anthropogenic activities; and 

4. The rehabilitated sea otter must not exhibit any aberrant behavior including behavior that may 

pose an unusual threat to human health and safety, wild sea otter populations, or other marine 

mammal populations. 

6.4 Medical Assessment of Sea Otters 

All rehabilitated sea otters must have a comprehensive, hands-on physical examination by a 

veterinarian experienced in sea otter medicine prior to release. The attending veterinarian must 

determine that the sea otter is likely to survive in the wild and must certify that: 

1. Blood sampling performed within two weeks of the proposed release date, including a CBC 

and serum chemistry profile, falls within normal ranges for the species; 

2. Medical diagnostic tests performed within two weeks of the proposed release date (e.g., 

cultures, biopsies, urinalysis, serology, virology, parasitology, immunology, etc) fall within 

normal parameters for the species or indicate a satisfactory state of health (reference CRC 

Handbook of Marine Mammal Medicine, 2nd Edition, Dierauf and Gulland 2001); 

3. The rehabilitated sea otter should be free of drug residues (excluding sedatives used for 

transport or to facilitate physical examinations) and maintain good clinical health for two 

weeks prior to release or for a period that satisfies the attending veterinarian that the animal is 

healthy; 
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Release February 2009 

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4. The rehabilitated sea otter must have functional vision and hearing, reasonable dental health, 

and good control and function of all appendages, at least to the degree that its survival in the 

wild is not compromised; and 

5. The rehabilitated sea otter does not pose a known threat (e.g., transmission of pathogens, 

congenital defects) to the wild sea otter populations or human health and safety. 

6.5 Release Categories for Sea Otters 

Despite the best efforts to rehabilitate stranded sea otters, many animals die or can never be released 

to the wild. The following categories have been identified to help determine the status of sea otters 

being held for rehabilitation: 

1. “RELEASABLE”: All rehabilitated sea otters meeting the medical and behavioral criteria 

listed above shall be considered releasable. Every effort should be made to release these 

animals to the wild as soon as they are deemed fit for release. 

2. “CONDITIONALLY RELEASABLE”: All live-stranded sea otters admitted to a 

rehabilitation program shall be considered conditionally releasable pending the outcome of 

rehabilitative treatments and a full medical examination and behavioral evaluation. 

3. “NON-RELEASABLE”: Sea otters that fail to meet one or more of the required criteria for 

release may be considered non-releasable. Rehabilitation facilities that believe that they may 

have an animal that is non-releasable must contact FWS (as identified in Appendix H) for 

concurrence on this finding and eventual disposition of the animal. Once FWS has 

determined that a sea otter is non-releasable, the holding facility may request a permit for 

permanent placement of the animal as long as the facility meets the requirements under 

section 104(c)(7) of the MMPA for non-depleted species, or section 104(c)(3) or (c)(4) and 

section 10 of the ESA for depleted species. 

6.6 Identification of Sea Otters Prior to Release 

Rehabilitation facilities must affix colored and numbered “Temple” tags to the rear flippers of each 

sea otter prior to release. In addition, a PIT tag must be implanted in the right inguinal area of each 

otter. With an appropriate scientific research permit issued by FWS, the rehabilitation facility may 

implant an abdominal VHF transmitter to facilitate post-release tracking and monitoring of the 

animals. In all cases, the selection of identification numbers, tag colors/positions, and VHF 
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Release February 2009 

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frequencies must be coordinated with other facilities and researchers in the area that sea otters are 

released. 

6.7 Release Site Selection for Sea Otters 

All rehabilitated sea otters should be released at or near the site where they originally stranded. In 

cases where this is not feasible, other release sites may be considered under existing Federal permits, 

letters of authorization, or through consultation with personnel from the FWS (as identified in 

Appendix H). In all cases, rehabilitated sea otters must be released into the same stock or population 

from which they originated. 

6.8 Post-Release Monitoring of Sea Otters 

All facilities releasing rehabilitated sea otters must establish a post-release monitoring program 

appropriate for each sea otter. The purpose of post-release monitoring is to determine the success of 

rehabilitation efforts and provide an opportunity for rescue of animals not able to make the transition 

back to the wild. Sea otters brought into rehabilitation as young pups must be tracked intensively 

immediately after release. Juveniles or sub-adults may require a focused effort while adult animals 

may be tracked opportunistically. Sea otters implanted with VHF transmitters should be tracked and 

monitored periodically for the duration of the battery life of the transmitters (i.e., 1-3 years). 
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

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7. Policies Regarding Release of Rehabilitated Polar Bears 

Polar bears occur in most ice-covered seas of the Northern Hemisphere and are circumpolar in 

distribution, although not continuously. Off the Alaskan coast, they normally occur as far south as 

the Bering Strait. In the Beaufort and Chukchi seas, polar bears make extensive migrations between 

the United States and Canada or Russian territories, respectively. These movements are thought to be 

related to seasonal and annual changes in ice position and condition. 

Polar bears normally found stranded in Alaska and subsequently recovered are generally orphaned 

cubs-of-the-year that are either incapable of fending for themselves or have not yet developed the 

skills to adequately survive in the wild. While these animals are temporarily placed in facilities for 

the purposes of rehabilitation and release, in the long term, it is highly unlikely that such cubs would 

be suitable for release back into the wild. Hunting and survival skills are learned during the 2 1⁄2 year 

dependence on the mother, are not innate to polar bear cubs, and will not be developed in captivity. 

For the reasons noted above, the FWS considers polar bear cubs to be poor candidates for release into 

the wild. If releases were to occur the predicted likely outcomes would be death by starvation or 

death caused by a predacious attack of another polar bear. Further, adoption by another family group 

is unlikely or impractical due to the low probability of encountering a receptive family group. 

Adoption of cubs into family groups has been attempted in Canada with very poor success and 

Canada is re-evaluating the feasibility of adoption as a management technique. The process of 

adoption requires substantial investment in searching out a family group in the wild, capture of the 

group (assisted by helicopter), and placement and follow-up on the fate of the adoptee. In Alaska, 

holding facilities co-located near release sites are not available. Therefore, FWS does not consider 

adoption to be a viable alternative and generally consider polar bear cubs to be non-releasable and 

more suitable for permanent placement in public display facilities. In these cases, the holding facility 

may request a permit for permanent placement of the animal as long as the facility meets the 

requirements under section 104(c)(7) of the MMPA. However, FWS will continue to evaluate 

potential release into the wild or permanent placement in public display facilities on a case-by-case 

basis. Questions regarding disposition of stranded polar bears must be directed to the FWS as 

identified in Appendix H. 
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

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8. References 

Dierauf and 

Gulland 2001 

Dierauf, L.A. and F.M.D. Gulland (eds.). 2001 CRC Handbook of Marine Mammal 

Medicine. CRC Press, Boca Raton, FL. 

Ewald 1993 Ewald, Paul. W. 1993. Host-parasite relations, vectors, and the evolution of disease 

severity. Annual Review of Ecological Systems 14: 465-485. 

Geraci and 

Lounsbury 2005 

Geraci, J.R. and V.J. Lounsbury. 2005. Tagging and monitoring. Marine Mammals 

Ashore: A Field Guide for Strandings, Second Edition. National Aquarium in 

Baltimore, Baltimore, MD. 

Gilmartin et al. 

1993 

Gilmartin, W., E. Jacobson, W. Karesh, and M. Woodford. 1993. Working group 

report: Monitoring, investigation, and surveillance of disease in free-ranging 

wildlife. Journal of Zoo and Wildlife Medicine 23(3): 389-393. 

Griffith et al. 

1993 

Griffith, B., J.M. Scott, J.W. Carpenter, and C. Reed. 1993. Animal translocations 

and potential disease transmission. Journal of Zoo and Wildlife Medicine 24(3): 

231-236 

Measures 2004 Measures, L.N., 2004. Marine mammals and “wildlife rehabilitation” programs. 

Canadian Science Advisory Secretariat Research Document 2004/122. 35 pp 

http://www.dfo-mpo.gc.ca/csas/. 

Moore et al. 

2007 

Moore, M., G. Early, K. Touhey, S. Barco, F. Gulland, and R. Wells. 2007. 

Rehabilitation and release of marine mammals in the united states: risks and 

benefits. Marine Mammal Science 23(4): 731-750 

Odegaard and 

Krogsrud 1981 

Odegaard, O.A. and J.Krogsrud. 1981. Rabies in Svalbard: infection diagnosed in 

arctic fox, reindeer, and seal. Veterinary Record 109: 141-142. 

Spalding and 

Forrester 1993 

Spalding, M.G. and D.J. Forrester. 1993. Disease monitoring of free-ranging and 

release wildlife. Journal of Zoo and Wildlife Medicine 24(3):271-280. 

St. Aubin and 

Dierauf 2001 

St. Aubin, D.J. and, L.A. Dierauf. 2001. Stress and marine mammals. In CRC 

Handbook of Marine Mammal Medicine. Edited by L.A. Dierauf and F.M.D. 

Gulland, CRC Press, Boca Raton, FL. 

Stoddard et al. 

in press 

Stoddard, R.A., E.R. Atwill, P.A. Conrad, B. Byrne, S. Jang, , J. Lawrence, B. 

McCowan and F.M.D. Gulland, In press. The effect of rehabilitation and use of 

antimicrobial drugs in northern elephant seals (Mirounga angustirostris) on 

antimicrobial resistance of commensal Escherichia coli. Veterinary Microbiology. 

Su et al. 2003 Su, C., D. Evans. R.H. Cole, J.C. Kissinger, J.W Ajioka, and L.D. Sibley. 2003. 

Recent expansion of toxoplasma through enhanced oral transmission. Science 229: 

414-416. 
Best Practices for Marine Mammal Response, Rehabilitation, and Release 

Standards for Release February 2009 

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APPENDIX A 

Chronology of Development of the Release Criteria

1977 1st Workshop on Marine Mammal Strandings; sponsored by the Marine Mammal 

Commission - Geraci, J.R. and D. J. St Aubin (eds.) 1979. Biology of marine mammals: Insights 

through strandings. Marine Mammal Commission. Report. No. MMC-77/13. U.S. Department 

of Commerce, NTIS Doc. PB 293 890, 343 p. (August 1977- Athens, GA). 

One of the workshop objectives was to provide recommendations regarding the handling, care, 

and disposition of live-stranded animals. A relevant finding that came from this workshop and 

was published in the proceedings included that if live-stranded animals are rescued and 

rehabilitated, decisions whether these animals should be released or maintained in captivity must 

take into account the possibility that the animals may have lost their natural capacity to locate 

and capture appropriate prey species, avoid predators, and interact normally with other members 

of the species. 

1987 2nd Workshop on Marine Mammal Strandings; sponsored by the Marine Mammal 

Commission and the National Marine Fisheries Service - Reynolds, J.E. and D.K. Odell (eds.) 

1991. Marine mammal strandings in the United States: proceedings of the second marine 

mammal stranding workshop; 3-5 December 1987, Miami, FL. U.S. Department of Commerce., 

NOAA Technical Report. NMFS 1998. 

A recommendation that came from this workshop and was published in the proceedings was a 

call to establish guidelines and procedures for determining whether and how live-stranded 

animals should be marked and returned to the sea, transported to a holding facility, rehabilitated, 

and subsequently released or maintained in captivity, or euthanized to avoid further pain and 

suffering. 

1991 Workshop on rescue, rehabilitation, and release of marine mammals; sponsored by the 

Marine Mammal Commission and the National Marine Fisheries Service - St. Aubin, D.J., J.R. 

Geraci, and V.J. Lounsbury (eds.) 1996. Rescue, rehabilitation, and release of marine mammals: 

an analysis of current views and practices. Proceedings of a workshop December 3-5, 1991, Des 

Plaines, IL. U.S. Department of Commerce, NOAA Technical Memorandum NMFS-OPR-8, 65 

p. 

The participants were charged to address five critical questions as well as discuss other 

outstanding and relative issues. They made several recommendations to include the assembly a 

panel of medical and behavioral specialists to recommend criteria for assuring that released 

animals will prosper humanely and pose no undesirable risk to the wild population. The 

guidelines should include a recommended set of medical determinations by species, with 

appropriate reference ranges for blood constituents and other clinical measures, morphometric 

limits (weight at length and age), a checklist for physical examination, and a means of scoring 

behavioral attributes that would influence survival in the wild. Minimum values should be set 

for each of these criteria, such that no animal failing any measure would be released. The panel 
would incorporate the recommendations of the group considering the risks associated with 

specific pathogens, particularly for “carriers” that are otherwise normal and healthy. The 

participants also made recommendations on disease transmission and monitoring. 

1992 Amendment of MMPA Title IV - 16 U.S.C. 1421a, Sec. 402. (a) DETERMINATION 

FOR RELEASE. The Secretary shall, in consultation with the Secretary of the Interior, the 

Marine Mammal Commission, and individuals with knowledge and experience in marine 

science, marine mammal science, marine mammal veterinary and husbandry practices, and 

marine conservation, including stranding network participants, develop objective criteria, after 

an opportunity for public review and comment, to provide guidance for determining at what 

point a rehabilitated marine mammal is releasable to the wild. Sec 402 (b) COLLECTION - The 

Secretary shall, in consultation with the Secretary of the Interior, collect and update, periodically, 

existing information on – (1) procedures and practices for – (A) rescuing and rehabilitating 

stranded marine mammals, including criteria used by stranding network participants, on a 

species-by-species basis, for determining at what point a marine mammal undergoing rescue and 

rehabilitation is returnable to the wild. 

1994 Expert Panel on Behavior, Life History, and Natural History Criteria for Release of 

Rehabilitated Marine Mammals

Acting on the findings of the 1991 workshop entitled “Workshop on rescue, rehabilitation, and 

release of marine mammal,” NMFS consulted with the Working Group on Unusual Marine 

Mammal Mortality Events to develop draft criteria. An expert panel of 12 biologists, 

veterinarians, and animal care professionals was queried by Dr. Randall Wells of the Chicago 

Zoological Society in August 1994 to address 12 specific questions on marine mammal behavior, 

life history, and natural history relative to release. Dr. Wells submitted a report summarizing the 

panel’s responses to NMFS in November 1994, and reported the findings at the annual meeting 

of the Marine Mammal Commission in November 1994. This report included recommendations 

for release criteria, preparations for release, release, follow-up monitoring, and dissemination of 

findings. These recommendations were included in the draft document. 

1994 Model for Marine Mammal Medical Criteria for Introduction to the Wild

 

In 1994, Dr. Gregory Bossart of the University of Miami, School of Medicine established a 

committee of seven nationally-recognized marine mammal veterinarians to formulate a draft of 

medical criteria that would act as guidelines for the re-introduction of wild marine mammal 

species. Marine mammal species included in this draft were cetaceans, pinnipeds, sea otters, and 

manatees. This draft was submitted to NMFS and became the working template for the present 

NMFS draft release medical guidelines. 

1996 Final Rule NMFS 50 CFR Sec. 216.27(a) require release of a marine mammal held for 

rehabilitation within six months of capture unless “...the attending veterinarian determines that: 

(i) The marine mammal might adversely affect marine mammals in the wild (ii) Release of the 

marine mammal to the wild will not likely be successful given the physical condition and 

behavior of the marine mammal; or (iii) More time is needed to determine whether the release of 

the marine mammal in the wild will likely be successful...” 
1991-1997 Working Group of Marine Mammal Unusual Mortality Events – This group 

established under Title IV of the Marine Mammal Protection Act closely guided the development 

of the first draft that was published in 1998. 

1998 FR Notice Draft NOAA Technical Memorandum - NMFS and FWS Release for 

Stranded Marine Mammals to the Wild: Background, Preparation, and Release Criteria 

Vol.63, No. 67/ Wed, April 8, 1998 

A notice of availability and request for comments was published in the Federal Register. 

2001 April 24, 2001 Summary of Public Comments on Draft NOAA Technical 

Memorandum - NMFS and FWS Release for Stranded Marine Mammals to the Wild: 

Background, Preparation, and Release Criteria 

NMFS received official responses from 20 individuals or organizations. There were several 

outstanding issues that required more development and clarification. NMFS decided to convene 

special working groups to address the comments. 

2001 Working groups on pinnipeds and cetaceans 

Three working groups were assembled by NMFS and FWS to address outstanding issues noted 

during the public comment period. Their recommendations have been incorporated into the 

current document. 
APPENDIX B 

Key Legislation: Marine Mammal Rescue, Rehabilitation, 

and Release to the Wild

• Marine Mammal Protection Act (MMPA) of 1972 

o Title I. - Conservation and Protection of Marine Mammals 

 Section 109 (h) - Taking of Marine Mammals as Part of Official Duties 

 Section 112 (c) - Contracts, Leases, and Cooperative Agreements 

o Title IV. - Marine Mammal Health and Stranding Response 

 Sec. 402 (a) - Determination for Release 

 (b) (1) – Procedures and Practices 

• Endangered Species Act of 1973, as amended 

• Code of Federal Regulations, Title 50, part 216 – Regulations governing the taking 

and importing of marine mammals

o Section 22 – Taking by the State or Local Government Officials 

o Section 27 - Release, Non- Releasability, and Disposition Under Special 

Exception Permits for Rehabilitated Marine Mammals 

 (a) Release Requirements, (b) Non-releasability and postponed 

determinations, (c) Disposition for special exceptions purposes, (d) 

Reporting 

o Subpart D – Special Exceptions for Threatened and Endangered Marine Mammals 

 Marine Mammal Health and Stranding Response Program Enhancement 

Permit 

• Code of Federal Regulations, Title 50, part 18 – Marine Mammals

o Section 22 – Taking by Federal, State, and Local Government Officials

o Section 31 – Scientific Research Permits and Public Display Permits

• Code of Federal Regulations, Title 50, part 17 – Endangered and Threatened 

Wildlife and Plants 

o Section 21 (c)(3) – Endangered Wildlife Prohibitions – Take 

o Section 31 (b) – Threatened Wildlife Prohibitions

o Section 22 – Endangered Wildlife Permits for Scientific Purposes, Enhancement 

of Propagation of Survival, or for Incidental Taking 

o Section 32 – Threatened Wildlife Permits - General 

 
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APPENDIX C 

REQUIRED REPORTING AND DOCUMENTATION 

Marine Mammal Stranding Report - Level A Data (NOAA 89-864, OMB #0648-0178) 

Marine Mammal Rehabilitation Disposition Report (NOAA 89-878, OMB #0648-0178) 

Manatee Rescue, Rehabilitation and Release Report 
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Manatee Rescue, Rehabilitation, and Release Report Fields

Rescue: Reporting 

Requirements

Release: Request 

Information

Transfer: Request 

Information

Death: 

Reporting 

Requirements

Captive Birth: 

Reporting 

Requirements

Name of Reporting 

Organization 

Date Report Filed 

Date Event Occurred 

Type of Rescue 

Identification 

 Name (if any) 

 Studbook 

Number 

 Identification 

Numbers (in the 

case of multiple 

numbers, all 

numbers should be entered) 

PIT Tag 

 Right 

(identifying 

number) 

 Left (identifying 

number) 

Freeze Brand (yes/no) 

 Number 

Sex 

Weight (lbs/kg) 

 Actual/estimated 

Length (cm/inches) 

 Actual/estimated 

Ultrasound (yes/no) 

County 

Nearest Town/Community 

Waterbody 

Latitude/Longitude 

Probable Cause for Rescue 

 (Drop down list 

includes various 

common causes; 

additional 

information is required for 

entangled animals) 

Health Status at Time of 

Report 

Rehabilitation Facility (if 

any) 

Veterinarian 

Facility Supervisor 

Rescue Participants 

Name of Reporter 

Telephone Number 

Name of Requesting 

Organization 

Date Request Filed 

Date Event Proposed 

Identification 

 Name (if any) 

 Studbook 

Number 

 Identification 

Numbers (in the 

case of multiple 

numbers, all 

numbers should 

be entered) 

PIT Tag 

 Right 

(identifying 

number) 

 Left (identifying 

number) 

Freeze Brand (yes/no) 

 Number 

Other Tags 

Name of Tracker/Affiliation 

Tracker Telephone Number 

Sex 

Weight (lbs/kg) 

 Actual 

 Date Taken 

Length (cm/inches) 

 Actual 

 Date Taken 

Peduncle Girth (cm) 

 Date Taken 

Ultrasound (yes/no) 

County Where Rescued 

Nearest Town/Community 

Waterbody 

Latitude/Longitude 

Date of Rescue 

Weight at Time of Rescue 

Length at Time of Rescue 

Proposed Date of Release 

Actual Date of Release 

County Where Released 

Nearest Town/Community 

Where Released 

Waterbody Where Released 

Veterinarian 

Facility Supervisor 

Release Participants 

Name of Reporter 

Telephone Number 

Name of Requesting 

Organization 

Date Request Filed 

Date Event Proposed 

Identification 

 Name (if 

any) 

 Studbook 

Number 

 Identification 

Numbers (in 

the case of 

multiple 

numbers, all 

numbers 

should be 

entered) 

Sex 

Weight (lbs/kg) 

 Actual 

 Date Taken 

Length (cm/inches) 

 Actual 

 Date Taken 

Date Brought Into 

Captivity 

Date of Proposed 

Transfer 

Actual Date of Transfer 

Veterinarian 

Facility Supervisor 

Release Participants 

Name of Reporter 

Telephone Number 

Name of Reporting 

Organization 

Date Report Filed 

Date Died 

Identification 

 Name (if 

any) 

 Studbook 

Number 

 Identificat

ion 

Numbers 

(in the 

case of 

multiple 

numbers, 

all 

numbers 

should be 

entered) 

Sex 

Date Rescued 

Probable Cause of 

Death (or 

Euthanized) 

Disposition of 

Carcass 

Veterinarian 

Facility Supervisor 

Name of Reporter 

Telephone Number 

Name of Reporting 

Organization 

Date Report Filed 

Date Born 

Identification 

 Name (if 

any) 

 Studbook 

Number 

 Identification 

Numbers (in 

the case of 

multiple 

numbers, all 

numbers 

should be 

entered) 

Sex 

Weight (lbs/kg) 

 Actual 

 Date Taken 

Length (cm/inches) 

 Actual 

 Date Taken 

Present Health Status 

Origin of Dam 

Circumstances of Birth 

Dam Identification 

 Name (if 

any) 

 Studbook 

Number (if 

any) 

 Identification 

Numbers (in 

the case of 

multiple 

numbers, all 

numbers 

should be 

entered) 

Sire Identification 

 Name (if 

any) 

 Studbook 

Number (if 

any) 

 Identification 

Numbers (in 

the case of 

multiple 

numbers, all 

numbers 

should be 

entered) 
APPENDIX D 

DISEASES OF CURRENT CONCERN FOR CETACEANS

The diseases listed below are of current concern for cetaceans. Numerous additional diseases 

exist among cetaceans and should also be considered during diagnostic work-ups. Testing for 

specific diseases of cetaceans is not required at this time. However, thorough diagnostic testing 

of rehabilitated cetaceans is strongly recommended as warranted by their history and clinical 

signs of illness. Clinicians are particularly encouraged to test cetaceans for brucellosis and 

morbillivirus. NMFS may require disease testing for specific individuals prior to release if 

concern for the health of wild marine mammals exists or concern exists regarding the animal’s 

likelihood of survival in the wild. Contact the NMFS coordinator for information regarding the 

appropriate diagnostic laboratories. 

A good resource to obtain updated literature on diseases of marine mammals is through the 

Animal Welfare Information Center (http://awic.nal.usda.gov), part of the United States 

Department of Agriculture National Agriculture Library. 

BACTERIAL DISEASES COMMENTS 

Brucellosis Serologic evidence or isolation of this bacterium has been made 

several species of cetaceans as well as those in captivity. Different 

serovar than terrestrial species. Current limited understanding of 

pathophysiology and significance. May cause reproductive illness, 

isolated from an aborted captive bottlenose dolphin fetus. 

Zoonotic. Human case followed handling of marine mammal 

tissues. (Dunn et.al., 2001; Brew et al., 1999; Clavareau, 1998; 

Miller, et.al., 1999). 

Erysipelothrix Has caused acute septicemia or generalized dermatitis in several 

cetacean species including wild orca. Believed to be acquired from 

ingestion of fish contaminated with the organism. Zoonotic, causes 

dermatitis, arthritis, pneumonia, or septicemia in humans. (Dunn 

et.al., 2001; Young et.al., 1997; Cowan et.al., 2001.) 

Respiratory Illness Respiratory illness is common among both captive and wild 

cetaceans. Such disease often involves bacterial pathogens and is 

frequently fatal. Staphylococcus areus and Pseudomonas 

aeruginosa as well as Gram negative bacterial organisms are often 

involved. Pulmonary parasitism may contribute to development of 

bacterial respiratory disease. (Dunn et.al., 2001; Howard 

et.al.1983; Kinoshita et al. 1994). 
VIRAL DISEASES 

Morbillivirus Has caused major epizootics with high mortalities in bottlenose 

dolphins, common dolphins, and striped dolphins. Has also 

infected other cetacean species. Testing for cetacean morbillivirus 

is strongly recommended for all cetaceans in rehabilitation centers. 

(Kennedy-Stoskopf, 2001; Kennedy, 1998; Duigan, 1999). 

Poxvirus Common infection of captive and wild cetaceans characterized by 

skin lesions. Not known to cause systemic infection. Appearance 

of lesions may correlate with weaning, poor general health, and/or 

compromised environmental conditions. (Kennedy-Stoskopf, 

2001; Van Bressem and Van Waerebeek ,1996; Geraci et.al. 1979). 

Papillomavirus Has caused lesions of the skin, genital area, stomach ,and tongue of 

several cetacean species. Sometimes referred to as benign tumors. 

 Genital lesions may be transmitted venereally and may interfere 

with copulation. (Kennedy-Stoskopf, 2001; Deguise et.al., 1994; 

Van Bressem et al., 1996). 

PARASITIC DISEASES 

Toxoplasmosis gondii Protozoan parasite which has caused serious disease and death in 

cetacean species. Source of infection not clearly defined. (Dailey, 

2001; Migaki, 1990.) 

 

Anasakid nematodes Family of nematodes which parasitize the cetacean gastrointestinal 

tract. Infections may cause gastritis and ulceration. (Dailey, 2001; 

Smith, 1989). 

Hepatic trematodes Heavy infection may cause serious liver disease associated with 

weight loss, increased susceptibility to bacterial infection. May 

result in death. 

 (Dailey, 2001; Zam et.al, 1971.) 

Nasitrema sp. Nematode parasite which infects nervous systems of cetaceans. 

May be a significant cause of stranding in odontocetes. Causes 

eighth cranial neuropathy, encephalitis, and cerebral necrosis. 

(Dailey, 2001). 

Lungworms Includes nematode genera such as Halocercus which may cause 

severe respiratory disease and may cause death, depending on 

severity of infection. (Dailey,2001; Measures, 2001; Moser and 

Rhinehart, 1993). 
NONINFECTIOUS DISEASES 

Anthropogenic trauma Entanglement in debris such as fishing nets and lines, collisions 

with boats, and underwater detonation of explosives may injure or 

kill cetaceans. The number of animals affected relative to total 

population may cause particular concern for some species (i.e. 

right whales and boat collisions, small odontocetes and fisheries 

by-catch). (Gulland et al. 2001, Kraus, 1990, Perrin et.al., 1994). 

Biotoxins Toxins naturally produced from dinoflagellates and diatoms have 

been associated with illness and death in cetaceans. Brevetoxin 

was a possible cause of bottlenose dolphin mortality in 1946-47 

and 1987-1988. Humpback whale mortality was associated with 

consumption of mackerel containing saxitoxin. (Gunter et.al., 

1948; Geraci, et.al., 1989). 

Neoplasia Belugas of the St. Lawrence River have had a concerning rate of 

neoplasia. Other cases of neoplasia have been reported in several 

species. Etiology of cetacean tumors is not known. Interplay of 

physical, chemical, and/or infectious agents with host factors such 

as age, sex, and genetic make-up likely involved with 

tumorigenesis. (Gulland et.al., 2001; De Guise et.al., 1994). 
THIS PAGE INTENTIONALLY LEFT BLANK
APPENDIX E 

DISEASES OF CURRENT CONCERN FOR PINNIPEDS

The diseases listed below are of current concern for pinnipeds. Numerous additional diseases 

exist among pinnipeds and should also be considered during diagnostic work-ups. Testing for 

specific diseases of pinnipeds is not required at this time. However, thorough diagnostic testing 

is strongly recommended for pinnipeds as warranted by their history and clinical signs of illness. 

NMFS, or in the case of walrus the FWS, may require disease testing for specific individuals 

prior to release if concern for the health of wild marine mammals exists or if there is significant 

concern regarding the animal’s likelihood of survival in the wild. Contact the NMFS 

coordinator, or the FWS in the case of walrus, for information regarding appropriate diagnostic 

laboratories. 

A good resource to obtain updated literature on marine mammal diseases is through the Animal 

Welfare Information Center (http://awic.nal.usda.gov), part of the United States Department of 

Agriculture, National Agriculture Library. 

BACTERIAL DISEASES COMMENTS 

Brucellosis Serologic evidence or isolation of this organism has been obtained 

for phocids and walrus. Different serovar than terrestrial species. 

Current limited understanding of pathophysiology and 

significance. May cause reproductive illness. Zoonotic. Human 

case followed handling of marine mammal tissues. (Dunn et.al., 

2001; Garner et. al., 1997). 

Leptospirosis Severe systemic illness that frequently affects California sea lions 

and northern fur seals. Infection may be obtained at sea, in 

rookeries, or via contact with fresh water sources contaminated by 

infected terrestrial mammals via contamination of water sources. 

May be treated with antibiotics. Zoonotic. (Dunn et.al., 2001; 

Schoenwald et. al., 1971; Gulland et.al., 1996, Stamper et al., 

1998). 

Mycobacterial Disease Illness characterized primarily by skin or pulmonary lesions 

diagnosed in several pinniped species. Caused by organisms which 

include those responsible for tuberculosis. Recently diagnosed in 

wild subantarctic fur seals. Zoonotic. (Dunn et. al., 2001, Cousins 

et.al., 1993, Bastida et.al., 1999). 
VIRAL DISEASES 

Adenovirus Caused fatal hepatitis in California sea lions. Source of virus 

unknown, but may be related to canine adenovirus. (KennedyStoskopf, 2001; Dierauf et.al., 1981). 

Calicivirus Several pinniped species susceptible. Causes skin lesions 

in California sea lions. Numerous animal species may be infected 

by calicivirus including fish, reptiles, mammals. Transmission 

from marine mammals to terrestrial animals and vice versa 

possible. Unconfirmed as zoonotic but possibility exists. 

(Kennedy-Stoskopf, 2001; Smith and Boyt, 1990; Gage, et.al., 

1990; Barlough et.al., 1998). 

Herpes Virus May infect several pinniped species including walrus. Causes fatal 

disease in neonatal Pacific harbor seals characterized by severe 

adrenal gland and liver pathology. (Kennedy-Stoskopf, 2001; 

Gulland et.al., 1997). 

Influenza Caused high mortality among Atlantic harbor seals. Endemic 

among this population. Changes in virulence may cause disease 

outbreaks. Related to avian influenza. Zoonotic. Has caused severe 

conjunctivitis among humans. (Kennedy-Stoskopf, 2001; Webster 

et.al., 1981). 

Morbillivirus Endemic in several phocid species. May cause high morbidity and 

mortality. Seals have been infected by the canine morbillivirus as 

well as a morbillivirus specific for phocids. (Kennedy-Stoskopf, 

2001; Kennedy, 1998; Duignan, 1999). 

Pox Causes skin lesions in several pinniped species. Outbreaks may be 

associated with stress as with postweanling animals recently 

introduced to captivity. Zoonotic. May cause skin lesions on 

humans. (Kennedy-Stoskopf, 2001; Hicks and Worthy, 1987). 

PARASITIC DISEASES 

Helminths A variety of nematode, trematode, and cestode parasites infect 

pinnipeds, causing varying degrees of clinical disease. For 

instance, the nematode Contracaecum corderoi has caused 

gastrointestinal perforations and fatal peritonitis in California sea 

lions. (Dailey, 2001; Fletcher, 1998.) 
Cryptosporidiosis Protozoan gastrointestinal parasite recently isolated from several 

pinniped species. Limited current knowledge of pathophysiology 

in pinnipeds. Zoonotic. (Miller, et.al., 2001; Deng, et.al., 2000). 

Giardia Protozoan gastrointestinal parasite identified in phocids and the 

California sea lion. Incidence and severity of clinical illness not 

fully understood. Zoonotic. (Miller, et.al., 2001; Measures and 

Olson, 1999.) 

Sarcocystis Protozoan parasite that may cause severe neurologic disease and 

death. Important cause of mortality among Pacific harbor seals. 

Organism may be found in waste from humans or their activities. 

(Miller, et. al., 2001; LaPointe, et.al., 1998). 

 

NONINFECTIOUS DISEASES 

Anthropogenic trauma Gunshot, underwater detonation of explosives, and entanglement 

in debris such as fishing nets and lines cause morbidity and 

mortality among pinnipeds. (Gulland, et.al., 2001). 

Biotoxins Harmful algal blooms producing domoic acid have caused 

significant sea lion mortality. (Gulland, 2000; Schoelin, et.al. 

2000). 

Neoplasia Carcinoma, an aggressive tumor often associated with the 

urogenital system is common in California sea lions. May be 

linked to viral infections and/or exposure to environmental 

contaminants. (Buckles, et.al., 1996, Gulland, et.al., 1996, 

Lipscomb, et.al., 2000). 
THIS PAGE INTENTIONALLY LEFT BLANK
APPENDIX F 

DISEASES AND ISSUES OF CURRENT CONCERN FOR MANATEES

The diseases and issues listed below are of current concern for manatees. Other diseases exist 

among manatees and should also be considered during diagnostic work-ups. Testing for specific 

diseases of manatees is not required at this time. However, thorough diagnostic testing of 

rehabilitated manatees is strongly recommended as warranted by their history and clinical signs 

of illness. FWS may require disease testing for specific individuals prior to release if concern for 

the health of wild marine mammals exists or concern exists regarding the animal’s likelihood of 

survival in the wild. Contact the FWS stranding support staff for information regarding the 

appropriate diagnostic laboratories. 

A good resource to obtain updated literature on marine mammal diseases is through the Animal 

Welfare Information Center (http://awic.nal.usda.gov), part of the United States Department of 

Agriculture National Agriculture Library. 

BACTERIAL DISEASES COMMENTS 

Brucellosis Antibodies to Brucella spp. have been reported in Florida 

manatees, although lesions consistent with brucellosis have not 

been observed (Geraci et al., 1999). 

Other Systemic mycobacteriosis due to Mycobacterium marinum and M. 

chelonei (Boever et al., 1976), and mycotic dermatitis (Dilbone, 

1965; Tabuchi et al., 1974), have been reported in adult manatees. 

VIRAL DISEASES 

Cutaneous papillomatosis Recently described in a captive population of manatees. PCR 

analyses has demonstrated a virus consistent with Type I bovine 

papilloma virus. (Bossart et al., 1998a) 

Morbillivirus Serologic evidence of morbillivirus has been demonstrated in 

manatees, although signs of clinical disease or active infection has 

not been observed (Duignan et al., 1995). 

Other Pseudorabies, San Miguel sea lion virus Type I, and eastern, 

western, and Venezuelan equine encephalitis have been reported in 

Florida manatees (Geraci et al., 1999). While these are 

serologically evident, no signs of clinical disease or active 

infection have been observed. 
PARASITIC DISEASES 

Meningoencephalitis Toxoplasma gondii has caused the death(s) of Florida manatees 

(Buerguelt and Bonde, 1983). 

Other Endoparasites are commonly found in manatees; however, 

pathological signs or clinical disease are rare (Bossart 2001). 

NONINFECTIOUS DISEASES 

Anthropogenic trauma Collisions with boats, entanglement in fishing gear (monofilament 

fishing line, crab float lines, etc.), crushing in water control 

structures, etc., are sources of injury and mortality 

Biotoxins Brevetoxins associated with Kerenia brevi and possibly other 

dinoflagellates have killed dozens of Florida manatees. Suspected 

vectors include ingestion of toxin-containing ascidians and sea 

grasses and inhalation of aerosolized toxicants (Bossart 2001). 

Cold stress syndrome Exposure to cold for extended periods of time initiates clinical 

signs and disease processes that characterize manatee cold stress 

syndrome. Effects include lethargy, anorexia, and terminal 

hypothermia. Numerous significant cold fronts extending the 

length of the Florida peninsula have caused deaths and cold stress 

in dozens of manatees aver the past few decades (Bossart 2001). 
APPENDIX G 

DISEASES OF CURRENT CONCERN FOR SEA OTTERS

The diseases listed below are of current concern for sea otters. Numerous additional diseases 

exist among sea otters and should also be considered during diagnostic work-ups. Testing for 

specific diseases of sea otters is not required at this time. However, thorough diagnostic testing is 

strongly recommended for sea otters as warranted by their history and clinical signs of illness. 

FWS may require disease testing for specific individuals prior to release if concern for the health 

of wild marine mammals exists or if there is significant concern regarding the animal’s 

likelihood of survival in the wild. Contact the FWS coordinator for information regarding 

appropriate diagnostic laboratories.

A good resource to obtain updated literature on marine mammal diseases is through the Animal 

Welfare Information Center (http://awic.nal.usda.gov), part of the United States Department of 

Agriculture, National Agriculture Library. 

BACTERIAL DISEASES COMMENTS 

Septicemias Overwhelming bacterial infections, sometimes from infected 

wounds, dental problems, and intestinal infections, are a common 

cause of mortality in southern sea otters, often secondary to 

infectional perforation by acanthocephalans (California 

Department of Fish and Game (CDFG) unpublished data), and a 

significant cause of mortality in northern sea otters in Alaska 

(FWS unpublished data). Connections with sewage or animal 

wastes are suspected in some infections; however, for northern sea 

otters, the source of this infection is often unknown. 

Valvular endocarditis This a sporadic disease secondary to chronic bacterial seeding 

from a primary source of infection such as a bite wound or tooth 

abscess. However, northern sea otters in Alaska have been 

diagnosed with VE without a primary source (FWS unpublished 

data). These animals have tested positive for the Streptococcus 

bovis/equinus complex. In human cases, there is an association 

between S.bovis endocarditis cases and a malignancy of the GI 

tract. 

Brucellosis One culture and PCR-confirmed case in a California sea otter with 

a chronic toe joint infection and low-level systemic disease (CDFG 

unpublished data). Fastidious in culture and easily missed. Marine 

Brucellae have demonstrated zoonotic potential, so caution is 

advised when handling fetal tissues, or live or dead animals with 

infected joints and wounds. 
Dental disease Dental disease is common, particularly in older animals and can 

lead to systemic bacterial infections. 

Leptospirosis Problem common in sea lions (see above pinniped section). 

Positive serologic titers in southern sea otters (Hanni et al. 2003). 

Cases reported in northern sea otters in Washington State. No 

clinical case identified in southern sea otters to date, although 

seropositive animals are observed. No cases reported for northern 

sea otters in Alaska. 

FUNGAL DISEASES 

Coccidiomycosis Low levels of infections (less than 1 percent) in southern sea otters, 

mostly off the San Luis Obispo county coast around the mouth of 

the Santa Maria River. Cases always fatal. Not reported in 

northern sea otters. Biohazard for people handling dead sea otters. 

 

VIRAL DISEASES 

Morbillivirus Conflicting evidence on whether exposure is relatively common or 

not in southern sea otters. Canine distemper has been diagnosed in 

a river otter in coastal British Columbia (Mos et al. 2003) and 

positive serologic titers have been noted in northern sea otters in 

Washington State. Care must be taken in moving otters if this virus 

is present in some populations and not others. Seropositivity to 

both canine and phocine distemper has been identified in northern 

sea otters in Washington and Alaska (FWS unpublished data). 

Papillomavirus Some evidence of this type of viral infection occurs, significance 

probably not great. Typically presents as small, raised variably 

pigmented plaques on the lips, tongue, or buccal mucosa. 

Occurrence often episodic and invariably incidental in southern sea 

otters (CDFG unpublished data). 

Herpesvirus Associated with corneal, oral, and esophageal ulcers, often in 

debilitated animals in California and Alaska. 
PARASITIC DISEASES 

Toxoplasma gondii Protozoan parasite which can cause serious disease and death in 

southern sea otters (Miller et al. 2004) and northern sea otters in 

Washington State. High prevalence of exposure in California with 

moderate mortality rate. There is evidence of wide exposure in 

California and Washington State (Lindsay et al. 2001; Miller et al. 

2002; Dubey et al. 2003; Conrad et al. 2005). Northern sea otters 

in Alaska rarely test positive (FWS unpublished data). Source of 

infection not clearly defined but hypothesized to be associated with 

freshwater inputs to the ocean in California (Miller et al. 2002; 

Dailey 2001; Migaki 1990). 

Sarcocystis neurona Protozoan parasite that may cause severe neurologic disease and 

death. Important cause of mortality among southern sea otters and 

northern sea otters in Washington State. Infections appear to 

progress more quickly than T. gondii (Miller et al. 2001; Miller 

2006). No evidence of this in northern sea otters in Alaska. 

Helminths A variety of nematode, trematode, and cestode parasites infect sea 

otters, causing varying degrees of clinical disease. 

Acanthocephalan thorny headed worms, particularly the 

Profilicollis spp. may be pathogenic when overwhelming 

infestations occur, particularly in young animals (Mayer et al. 

2003). 

Mites Nasal mite infestations are uncommon in wild animals, but heavy 

infections may occur in captive and rehabilitated animals. Heavy 

infections can result in secondary bacterial nasopharyngitis and 

pneumonia. 

Giardia Some live, captive northern sea otters in Alaska have tested 

positive (FWS unpublished data). 

NONINFECTIOUS DISEASES 

Anthropogenic trauma Gunshot, boatstrike, oil spills, and entanglement in debris such as 

fishing nets, fishing lines, and hooks cause morbidity and mortality 

among sea otters. Alaskan otters have died from impactions with 

fish bones when feeding at cannery outfalls (FWS unpublished 

data). 

Biotoxins Harmful algal blooms particularly those producing domoic acid 

have caused some morbidity and mortality of sea otters in 

California (Gulland 2000; Jessup et al. 2004). 
Persistent Organic Levels in southern sea otters and northern sea otters in Alaska 

Pollutants adjacent to known military dump sites are high (50-100 times 

control populations). Potential effects on endocrine and immune 

functions are a cause for concern, but evidence for this or for acute 

toxicity are lacking. 

Predation White shark predation on southern sea otters is well documented. 

Some cases may be secondary to brain infections or intoxications 

that render otters helpless. Killer whale predation is hypothesized 

to be very significant in the decline of certain northern sea otter 

populations in Alaska. 

Neoplasia A number of types of neoplasia have been documented in northern 

sea otters (FWS unpublished data). 

Intestinal Disease Sea otters have been known to suffer from intestinal 

intussusceptions, torsions, and impactions not caused by human 

related causes. 

Conspecific Trauma Territorial males will often attack other male or pups. Males may 

also injure females during mating. 
References:

Conrad, P.A., M.A. Miller, C. Kreuder, E.R. James, J. Mazet, H. Dabritz, D.A. Jessup, F. 

Gulland, and M.E. Grigg. 2005. Transmission of Toxoplasma: 

Clues from the study of sea otters as sentinels of Toxoplasma 

gondii flow into the marine environment. International Journal for 

Parasitology 35:1155-1168. 

Dailey, M. D. 2001. Parasitic Diseases. In CRC Handbook of Marine Mammal Medicine, 2nd 

Edition L. A. Dierauf and F. M. D. Gulland (eds.). CRC Press, 

Boca Raton, Florida. Pp. 309-335. 

Dubey, J.P., R. Zarnke, N.J. Thomas, S.K. Wong, W.Van Bonn, M. Briggs, J.W. Davis, R. 

Ewing, M. Mense, O.C.H. Kwok, S. Romand, and P. Thulliez. 

2003. Toxoplasma gondii, Neospora caninum, Sarcocystis 

neurona, and Sarcocystis canis-like infections in marine mammals. 

Veterinary Parasitology 116:275-296. 

Gulland, F. 2000. Domoic acid toxicity in California sea lions (Zalophus californianus) 

stranded along the central California coast, May-October 1998. 

Report to the National Marine Fisheries Service Working Group 

on unusual Marine Mammal Mortality Events. US Dept. 

Commerce NOAA Technical Memorandum NMFS-OPR-17, 

December 2000. 

Hanni, K.D., J.A.K. Mazet, F.M.D. Gulland, J. Estes, M. Staedler, M.J. Muray, M. Miller, and 

D.A. Jessup. 2003. Clinical pathology and assessment of 

pathogen exposure in southern and Alaskan sea otters. Journal of 

Wildlife Diseases 39(4):837-850. 

Jessup D.A., M.A. Miller, M.Harris, B. Hatfield, J.A. Estes. 2004. The 2003 southern sea otter 

(Enhydra lutris nereis) unusual mortality event: A preliminary 

report to NOAA and USFWS. 

Lindsay, S.D., N.J. Thomas, A.C. Rosypal, and J.P. Dubey. 2001. Dual Sarcocystis neurona

and Toxoplasma gondii infection in a Northern sea otter from 

Washington state, U.S.A. Veterinary Parasitology 97:319-327. 

Mayer, K., M. Dailey and M. Miller. 2003. Helminth parasites of the southern sea otter (Enhydra 

lutris nereis) from central California: abundance, distribution and 

pathology. Diseases of Aquatic Organisms. 53:77-82. 

Migaki, G., Sawa, T.R. and Dubey, J.P. 1990. Fatal disseminated toxoplasmosis in a spinner 

dolphin (Stenella longirostris). Vet. Pathol. 27:463-464. 
Miller, M.A., P. R. Crosbie, K. W. Sverlow, K. Hanni, B. C. Barr, N. Kock, M. J. Murray, L. J. 

Lowenstine, A. Packham and P. A. Conrad. 2001. Isolation and 

characterization of Sarcocystis from brain tissue of a free-living 

southern sea otter (Enhydra lutris nereis) with fatal 

meningoencephalitis. Parasitology Research. 87:252-257. 

Miller, M..A., I.A. Gardner, A. Packham, J.K. Mazet, K.D. Hanni, D.A. Jessup, J. Estes, R. 

Jameson, E. Dodd, B.C. Barr, L.J. Lowenstine, F.M. Gulland and 

P.A. Conrad. 2002. Evaluation of an indirect fluorescent antibody 

test (IFAT) for demonstration of antibodies to Toxoplasma gondii

in the sea otter (Enhydra lutris). J. Parasitol. 88:594-599. 

Miller, M.A., M.E. Grigg, C. Kreuder, E.R. James, A.C. Melli, P.R. Crosbie, D.A. Jessup, J.C. 

Boothroyd, D. Brownstein, and P.A. Conrad. 2004. An unusual 

genotype of Toxoplasma gondii is common in California sea otters 

(Enhydra lutris nereis) and is a cause of mortality. International 

Journal for Parasitology 34:275-284. 

Miller, M. A. 2006. Tissue Cyst-Forming Coccidia of Marine Mammals. In: Zoo and Wildlife 

Medicine. M. Fowler and E. Miller, Eds: In press. 

Mos, L., P.S. Ross, D. McIntosh, and S. Raverty. 2003. Canine distemper virus in rivers otters 

in British Columbia as an emergent risk for coastal pinnipeds. 

Veterinary Record 152:237-239. 
THIS PAGE INTENTIONALLY LEFT BLANK
APPENDIX H 

Contact Information for NMFS and FWS National and 

Regional Stranding Support Staff

National Marine Fisheries Service

OFFICE ADDRESS PHONE 

Headquarters Office of Protected Resources 

Marine Mammal Health and 

 Stranding Response Program 

1315 East-West Highway 

Silver Spring, MD 20910 

Phone: (301) 713-2322 

Fax: (301) 427-2522 

Northeast Region Administrator, Northeast Region 

One Blackburn Drive 

Gloucester, MA 01930-2298 

Phone: (978) 281-9250 

Fax: (978) 281-9207 

Southeast Region Administrator, Southeast Region 

263 13th Ave. South 

St. Petersburg, FL 33701 

Phone: (727) 824-5301 

Fax: (727) 824-5320 

Northwest Region Administrator, Northwest Region 

7600 Sand Point Way, NE 

Bin C 15700, Bldg. 1 

Seattle, WA 98115-0070 

Phone: (206) 526-6150 

Fax: (206) 526-6426 

Southwest Region Administrator, Southwest Region 

501 West Ocean Blvd. Suite 4200 

Long Beach, CA 90802-4213 

Phone: (562) 980-4001 

Fax: (562) 980-4018 

Alaska Region Administrator, Alaska Region 

P.O. Box 21668 

Juneau, AK 99802-1668 

Phone: (907) 586-7221 

Fax: (907) 586-7249 

Pacific Islands 

Region 

Administrator, Pacific Islands 

 Region 

1601 Kapiolani Blvd., Suite 1110 

Honolulu, HI 96814 

Phone: (808) 944-2280 

Fax: (808) 973-2941 
U.S. Fish and Wildlife Service

OFFICE ADDRESS PHONE 

Headquarters Division of Habitat and Resource 

Conservation 

4401 N. Fairfax Drive, Room 400 

Arlington, VA 22203 

Phone: (703) 358-2161 

Fax: (703) 258-1869 

LOAs and Permits Division of Management Authority 

4401 N. Fairfax Drive, Room 700 

Arlington, VA 22203 

Phone: (703) 358-2104 

Fax: (703) 358-2281 

Manatees Jacksonville Field Office 

6620 Southpoint Drive South, Suite 

310 

Jacksonville, FL 32216 

Phone: (904) 232-2580 

Fax: (904) 232-2404 

Southern Sea 

Otters in 

California 

Ventura Field Office 

2493 Portola Road, Suite B 

Ventura, CA 93004 

Phone: (805) 644-1766 

Fax: (805) 644-3958 

Northern Sea 

Otters in 

Washington 

Washington Field Office 

510 Desmond Drive SE, Suite 102 

Lacey, WA 

Phone: (360) 753-9440 

Fax: (360) 753-9518 

Polar Bears, 

Pacific Walrus, 

and Northern Sea 

Otters in Alaska 

Marine Mammals Management 

Office 

1011 E. Tudor Road 

Anchorage, AK 99503 

Phone: (907) 786-3800 

Fax: (907) 786-3816 
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APPENDIX I 

Cetacean – Species Specific Developmental Stages (Age-Length) and Social 

Dynamics

Scientific Name Common 

Name

Approx 

Length 

at Birth 

(cm)

Approx 

"NEONATE

" length 

(cm)

Approx 

Length 

at 1 

Year of 

Age 

(cm)

Approx

Length 

at 2 

Years 

of Age 

(cm)

Approx

. Age at 

Weanin

g (yrs)

Approx 

Length 

at 

Weaning 

(cm)

Approx. 

Adult 

Length 

(cm)

Typical 

Group 

Size

Freq. of 

Occur. 

Single 

Individuals

Delphinapterus 

leucas Beluga Whale 160 130-160 216 250 2 250 

300-400 

F 400-

450 M 

up to 

hundreds uncommon 

Delphinus 

capensis 

Long-beaked 

Saddleback 

Dolphin 

< 100 

up to 

thousand

s 

uncommon 

Delphinus 

delphis 

Common 

Dolphin 80-90 80-100 110-120 230-250 

up to 

thousand

s 

uncommon 

Feresa attenuata Pygmy Killer 

Whale 80 240-270 1-70 occasional 

Globicephala 

macrorhynchus 

Short-finned 

Pilot Whale 140-185 150 2-3 

400-500 

F 500-

600 M 

up to 

several 

hundred 

rare 

Globicephala 

melas 

Long-finned 

Pilot Whale 177 160-200 2-3 240 

450-500 

F 450-

600 M 

up to 

several 

hundred 

rare 

Grampus 

griseus 

Risso's 

Dolphin 110-150 120-160 300-400 

single to 

several 

hundred 

occasional 

Kogia breviceps Pygmy Sperm 

Whale 120 100-120 1 300 - 370 1-6 not 

uncommon 

Kogia sima Dwarf Sperm 

Whale 95 100 1 210-270 1-10 not 

uncommon 

Lagenodelphis 

hosei 

Fraser's 

Dolphins 100 100 240 100-1000 uncommon 

Lagenorhynchus 

acutus 

Atlantic Whitesided Dolphin 108-122 100-130 142-156 176-190 1.5 180 240-270 2-500 uncommon 

Lagenorhynchus 

albirostris 

White Beaked 

Dolphin 110-120 110-130 300-320 1-100 (to 

1500) occasional 

Lagenorhynhchu

s obliquidens 

Pacific Whitesided Dolphin 92 80-100 220-230 

tens to 

thousand

s 

uncommon 

Lissodelphis 

borealis 

Northern Right 

Whale Dolphin 80-100 80-100 

220-230 

F 260-

300 M 

100-200 occasional 

Mesoplodon 

densirostris 

Blainville's 

Beaked Whale 200 450-470 1-7 occasional 

Mesoplodon 

europaeus 

Gervais' 

Beaked Whale 210 210 450-520 small 

groups uncommon 

Orcinus orca Killer Whale 183-228 210-250 1.5-2.0 400 

700-800 

F 800-

950 M 

2-100 infrequent - 

adult males 

Peponocephala 

electra 

MelonHeaded 

Whale 

100 270 150-1500 uncommon 

Phocoena 

phocoena 

Harbor 

Porpoise 70 70-90 110-135 115-155 0.3 - 1.0 100 - 110 140-170 small 

groups 

not 

uncommon 
Scientific Name Common 

Name

Approx 

Length 

at Birth 

(cm)

Approx 

"NEONATE

" length 

(cm)

Approx 

Length 

at 1 

Year of 

Age 

(cm)

Approx

Length 

at 2 

Years 

of Age 

(cm)

Approx

. Age at 

Weanin

g (yrs)

Approx 

Length 

at 

Weaning 

(cm)

Aprox. 

Adult 

Length 

(cm)

Typical 

Group 

Size

Freq. of 

Occur. 

Single 

Individuals

Phocoenoides 

dalli 

Dall's 

Porpoise 100 100 0.3-2.0 180-220 2-12 uncommon 

Physeter 

macrocephalus Sperm Whale 400 350-500 670 2+ 670 

1100-

1300 F 

1500-

1800 M 

20-40 

(50) adult males 

Pseudorca 

crassidens 

False Killer 

Whale 160 170-200 1.5-2.0 

500 F 

550-600 

M 

10-20+ rare 

Stenella 

attenuata 

Pantropical 

Spotted 

Dolphin 

85 80-100 129-142 1-2 140 120 

<100 to 

thousand

s 

uncommon 

Stenella clymene Clymene 

Dolphin 180-200 1-50 occasional 

Stenella 

coeruleoalba 

Striped 

Dolphin 93-100 100 166 180 170 220-260 10-100s uncommon 

Stenella frontalis 

Atlantic 

Spotted 

Dolphin 

100 80-120 140 200-230 1-15 uncommon 

Stenella 

longirostris 

Spinner 

Dolphin 76-77 70-80 133-137 1-2 180-220 

up to 

thousand

s 

uncommon 

Steno 

bredanensis 

Roughtoothed 

Dolphin 

100 240-270 10-20 uncommon 

Tursiops 

truncatus 

Bottlenose 

Dolphin 117 100-130 170-200 170-225 1.5-2.0 225 

220-300 

(coastal) 

250-650 

(offshore

) 

2-15 occasional 

Ziphius 

cavirostris 

Cuvier's 

Beaked Whale 270 200-300 670 - 700 1-7 not 

uncommon 
Pinniped – Species Specific Developmental Stages (Age-Length) and Pupping 

Information

Scientific Name Common Name

Approx 

Length at 

Birth (cm)

Approx 

"NEONATE" 

length (cm)

Approx. 

Age at 

Weaning

Approx

Length at 

Weaning 

(cm)

Approx. 

Adult Length

(cm)

Pups Born Peak of 

Pupping

Arctocephalus 

townsendi 

Guadalupe Fur 

Seal 60 60 9-11 

months 

140-170 F 

180-240 M June June 

Callorhinus ursinus Northern Fur Seal 60-65 60 3-4 

months 

100-150 F 

190-230 M June-July June-July 

Cystophora cristata Hooded Seal 90-100 90-110 4-12 days 200-230 F 

230-290 M Late March Late March 

Erignathus barbatus Bearded Seal 130 130 12-18 

days 150 210-250 

Mid-October 

to MidNovember 

End of 

October 

Eumetopias jubatus Steller Sea Lion 100 100 Within 1 yr 180 220-290 F 

240-330 M 

Mid-May to 

Mid-June Mid-June 

Halichoerus grypus Gray Seal 90-110 80-110 16-21 

days 110 180-210 F 220-250 M 

JanuaryFebruary January 

Histriophoca fasciata Ribbon Seal 80-90 80-90 3-4 weeks 90-110 150-180 April-May Early April 

Mirounga angustirostris Northern Elephant 

Seal 125 120-140 28 days 150 200-320 F 380-410 M January End of January 

Monachus schauinslandi Hawaiian Monk 

Seal 100 100 3-7 weeks 100 230-240 F 

210-220 M 

DecemberAugust March- May 

Odobenus rosmarus Walrus 100-120 100-140 2+ years 200 230-260 F 

270-320 M April-June May 

Pagophilus 

groenlandicus Harp Seal 85 80-110 12 days 100 160-190 FebruaryMarch March 

Phoca larga Spotted Seal 77-92 80-90 4-6 weeks 110 160-170 Early AprilEarly May Early April 

Phoca vitulina Harbor Seal 70-100 70-90 3-6 weeks 90 150-190 May-June May 

Pusa hispida Ringed Seal 60-65 60-70 6-8 weeks 80 120-150 Mid-March to 

Mid-April Early April 

Zalophus californianus California Sea Lion 75 70 10-12 

months 

150-200 F 

200-240 M June June 
References:

Marine Mammals Ashore: A Field Guide for Strandings second edition, J.R.Geraci and 

V.J.ounsbury, ©National Aquarium in Baltimore, 2005. 

Marine Mammals Ashore : A field guide for strandings J.R. Geraci and V.J. Lounsbury 

©SeaGrant College Program, Texas A&M University, 1993. ISBN: 1883550017 

Guide to Marine Mammals of the World. R.R. Reeves, B.S. Stewart, P.J. Clapham, and J.A. 

Powell. Chanticleer Press, Inc., New York, 2002. 

Seals of the World. Judith E. King Comstock Publishing Association, Cornell Press, Ithaca, 

New York, 1983 

Handbook of Marine Mammals Volume 4 River dolphins and the larger toothed whales.

Edited by Sam H. Ridgway and Richard Harrison. Academic Press, London, New York, 1989. 

ISBN: 0125885040

Handbook of Marine Mammals Volume 5 The first book of dolphins. Edited by Sam H. 

Ridgway and Richard Harrison. Academic Press, London, New York, 1994. ISBN: 0125885059

Handbook of Marine Mammals Volume 6 The Second book of dolphins and the porpoises. 

Edited by Sam H. Ridgway and Richard Harrison. Academic Press, San Diego, 1999.

ISBN: 0125885067 
APPENDIX J 

“Recommended” Standard Checklist to Determine Release Category of all Rehabilitated 

Cetaceans

Yes = true statement, No= untrue statement (shaded areas may not be applicable) 

Release 

Determination 

Assessment (within 2 

weeks of release) 

Pre-Release 

Assessment (within 

72 hours of release) 

History Yes No Yes No 

1. The release candidate has NOT previously stranded 

2. Stranding was NOT associated with a Marine Mammal Unusual 

Mortality Event or ongoing epidemic 

3. Stranding was NOT associated with anthropogenic 

environmental accident (e.g., hazardous waste spill, acoustic insult) 

4. Stranding was NOT associated with an environmental event of 

NMFS concern (e.g., harmful algal bloom, fish kill, etc.) 

5. Stranding was NOT associated with an El Niño event 

6. The animal is NOT evidence or part of a human interaction or 

criminal case 

7. Stranding was NOT associated with a mass stranding 

8. The animal was NOT part of a “permitted” research project 

Developmental Stage 

9. The release candidate is of sufficient size and age to be 

nutritionally dependent 

10. The release candidate is NOT a female with calf 

11. The release candidate is NOT a geriatric animal and is NOT 

compromised due to age related conditions. 

 

12. There is NO evidence that the release candidate was exposed to 

terrestrial wild or domestic animals prior to and during rehabilitation 

Behavioral Clearance 

13. The release candidate demonstrates appropriate breathing, 

swimming, and diving 

 

14. The release candidate does NOT exhibit aberrant behavior 

including attraction to or desensitization to the presence of humans 

 

15. The release candidate does NOT exhibit auditory or visual 

dysfunction 

 

16. The release candidate demonstrates appropriate foraging ability 

17. The release candidate did NOT strand as a direct result of a 

failure to avoid predators 

 
Release 

Determination 

Assessment (within 2 

weeks of release) 

Pre-Release 

Assessment (within 

72 hours of release) 

Behavioral Clearance (continued) Yes No Yes No 

18. The release candidate did NOT strand as a result of taking food 

from humans in the wild 

 

19. The release candidate did NOT strand as a direct result of a 

demonstrated inability to obtain sufficient food in the wild 

 

20. The release candidate did NOT strand as a direct result of a 

conspecifics injury 

Medical Clearance 

21. The attending veterinarian has reviewed the release candidate’s 

history and medical records, including records from other facilities 

that have previously held the animal. 

 

22. The attending veterinarian has examined the release candidate 

within two weeks of release 

 

23. The required health screen and assessments were conducted 

with good results 

 

24. Hands-on physical exam to be performed by attending 

veterinarian within 72 hours of release 

 

25. NO congenital defects 

26. CBC compatible with good health 

27. Chemistry profile compatible with good health 

28. Serum banked upon admission and prior to release (3 ml) 

29. Additional testing requested and reviewed by NMFS and no 

apparent concerns 

 

30. Free of drugs (exclusive of sedatives used for transport) 

minimum of 2 weeks prior to release 

 

31. Veterinarian’s signature on health statement 

Health Statement 

I have examined the cetacean (Species and ID#)___________________ on (Date) ______________ and have 

determined that the animal is medically and behaviorally suitable for release in accordance with the release criteria 

in that the animal will not pose a risk to the wild population and is likely to survive upon reintroduction to the wild. 

Signature of the Attending Veterinarian Printed Name of the Attending Veterinarian 

Signature of the Authorized Representative Printed Name of the Authorized Representative
“Recommended” Standard Checklist to Determine Release Category of all Rehabilitated 

Pinnipeds (except walrus)

Yes = true statement, No= untrue statement (shaded areas may not be applicable) 

Release 

Determination 

Assessment (within 2 

weeks of release) 

Pre-Release 

Assessment (within 

72 hours of release) 

History Yes No Yes No 

1. The release candidate has NOT previously stranded 

2. Stranding was NOT associated with a Marine Mammal Unusual 

Mortality Event or ongoing epidemic 

3. Stranding was NOT associated with anthropogenic 

environmental accident (e.g., hazardous waste spill, acoustic insult) 

4. Stranding was NOT associated with an environmental event of 

NMFS concern (e.g., harmful algal bloom, fish kill, etc.) 

5. Stranding was NOT associated with an El Niño event 

6. There is NO evidence that the release candidate was exposed to 

terrestrial wild or domestic animals prior to and during rehabilitation 

7. The release candidate is NOT known to have inflicted a bite on 

human(s) 

8. The animal is NOT evidence or part of a human interaction or 

criminal case 

9. The animal was NOT part of a “permitted” research project 

Developmental Stage 

10. The release candidate is weaned, and has a proven ability to feed 

itself 

11. The release candidate is sufficiently robust, having adequate 

reserves to survive readjustment in the wild 

12. The release candidate shows no sign of molt 

Behavioral Clearance 

13. The release candidate demonstrates appropriate breathing, 

swimming, diving, and locomotion on land 

 

14. The release candidate demonstrates an absence of aberrant 

behavior including attraction to or desensitization to the presence of 

humans 

 

15. The release candidate does NOT exhibit auditory or visual 

dysfunction 

 

 
Release 

Determination 

Assessment (within 2 

weeks of release) 

Pre-Release 

Assessment (within 

72 hours of release) 

Behavioral Clearance (continued) Yes No Yes No 

16. The release candidate demonstrates a capacity to chase and 

capture live prey 

 

Medical Clearance 

17. The attending veterinarian has reviewed the release candidate’s 

history and medical records, including records from other facilities 

that have previously held the animal. 

 

18. The attending veterinarian has examined the release candidate 

within two weeks of release 

 

19. The required health screen and assessments were conducted 

with good results 

 

20. Hands-on physical exam to be performed by attending 

veterinarian within 72 hours of release 

 

21. NO congenital defects 

22. NO nonfunctional or damaged appendages 

23. NO defects in vision 

24. CBC compatible with good health 

25. Chemistry profile compatible with good health 

26. Serum banked upon admission and prior to release (3 ml) 

27. Additional testing requested and reviewed by NMFS and no 

apparent concerns 

 

28. Free of drugs (exclusive of sedatives used for transport) 

minimum of 2 weeks prior to release 

 

29. Veterinarian’s signature on health statement 

Health Statement 

I have examined the pinniped (Species and ID#)___________________ on (Date) ______________ and have 

determined that the animal is medically and behaviorally suitable for release in accordance with the release criteria 

in that the animal will not pose a risk to the wild population and is likely to survive upon reintroduction to the wild. 

Signature of the Attending Veterinarian Printed Name of the Attending Veterinarian 

Signature of the Authorized Representative Printed Name of the Authorized Representative
THIS PAGE INTENTIONALLY LEFT BLANK 
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

NMFS Disentanglement Guidelines February 2009 

1 

NATIONAL MARINE FISHERIES SERVICE (NMFS) CRITERIA 

FOR DISENTANGLEMENT ROLES AND TRAINING LEVELS 

Levels of Participation in the Disentanglement Network – Definitions 

Roles Levels 

First Responder 1-5 

Primary First Responders 3-5 

Primary Disentanglers 4-5 

First Responder is a general term that is used to describe anyone in the Network with any level of 

training who may respond to an entanglement report under Network protocols and authorization. At a 

minimum they will voluntarily attempt to standby with an entangled whale and, depending on 

training, experience, authorization and equipment available, may also assess and perhaps tag the 

whale. Individuals with higher Network ratings (Levels 3-5) may act as Primary First Responders 

in local areas. Primary First Responders direct efforts locally and, under certain conditions and 

authorization, may attempt disentanglements during first response. These individuals have rapid 

access to vessels and specialized equipment. Additionally, Primary First Responders are on call fulltime or at least during those times when there is a high likelihood of an entanglement report in their 

area of responsibility. 

A First Responder's anticipated range of tasks is generally dependent on their classification in the 

Network. Classifications to various levels are determined on an individual basis and are based on a 

number of factors including, but not limited to the following: 

• Preexisting experience and skills 

• Willingness and commitment to build experience and improve skills 

• Training 

• Opportunity and available resources 

• Location 

• Commitment to being “on-call” 

• Commitment to respond as needed 
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

NMFS Disentanglement Guidelines February 2009 

2 

Primary Disentanglers are individuals who can perform all of the responsibilities of a first 

responder, but who also meet the criteria used by NMFS for selecting individuals who may undertake 

the very dangerous activity of disentangling (i.e. attaching to, stopping and cutting a whale free). 

Primary Disentanglers must have the experience, training, support and proper equipment at the time 

of the event to conduct a full disentanglement with a high likelihood of success. Primary 

Disentanglers are those rated at Level 4-5 in the Disentanglement Network. A summary of the 

various levels of certification follows. 

DISENTANGLEMENT NETWORK CERTIFICATION 

LEVEL 1 

Targeted Individuals: Professional mariners (i.e. fishermen, naturalists, Marine Patrol Officers) 

Boating experience and/or experience around whales is highly suggested (i.e. professional fishing, 

field biology, marine law enforcement, whale watching, etc.) 

Responsibilities 

Level 1 activities: report, standby, and assess (within experience) 

• Rapidly alert Disentanglement Network of first-hand and/or second-hand knowledge of local 

entanglements 

• Depending on experience, stand by an entangled whale until backup arrives, and/or 

• Communicate with crew on the vessel that is directly standing by the entangled whale and 

offer to replace the stand by vessel until additional backup or the response team arrives (if 

needed and within experience) 

Criteria for certification 

• Completed Level 1 classroom training, or

• Viewed Provincetown Center for Coastal Studies (PCCS) Training Video and demonstrated 

equivalent knowledge and experience (submit resume)

LEVEL 2 

Targeted Individuals: Professional mariners (i.e. fishermen, naturalists, Marine Patrol Officers). 

There is a higher expectation of commitment and participation from Level 2 responders. 
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

NMFS Disentanglement Guidelines February 2009 

3 

Responsibilities 

Level 2 activities: report, stand by, and assess at a higher level (within experience) 

• Provide a thorough assessment of the nature of the entanglement and the species, condition 

and behavior of the whale 

• Provide local knowledge, transportation, and assistance to Primary First Responders, as 

needed, on a voluntary basis 

• Be on call, as available, to assist in planned disentanglement operations on telemetry tagged 

whales 

Criteria for certification 

Level 1 certification in addition to the following: 

• Completed Level 2 on-water training, or 

• Viewed PCCS Training Video and demonstrated equivalent knowledge and experience 

(submit resume) 

LEVEL 3 

Targeted Individuals: Whale researchers and naturalists, fishermen, natural resource agency 

personnel, Marine Patrol Officers. 

Responsibilities 

Level 3 activities- report, stand by, assess, document and attach a telemetry buoy. Other activities 

may include: 

• Be on call 24 hours and should respond if conditions allow 

• Initiate and maintain preparedness with local fishing industry, Coast Guard, and other 

resources 

• Prepare local disentanglement action plan 

• Provide entanglement assessment, documentation and recommendations to Primary 

• Disentanglers during events 

• Attach telemetry equipment to entangling gear if needed and authorized 

• May be asked (depending on experience) to disentangle a minor entanglement with potential 

to adversely affect any whale other than right whales under the supervision/authorization of 
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

NMFS Disentanglement Guidelines February 2009 

4 

Level 4 or 5 network members. Authorization and supervision may be given over the phone 

or radio depending on the circumstances and level of experience. 

Criteria for certification 

Level 1 and 2 certification and experience in the following elements: 

• Large whale species identification and behavior, and the ability to safely follow a free 

swimming, entangled whale 

• Boat handling and safety including basic seamanship, driving, and close approaches to 

whales 

• Line handling and safety including knowledge of knots, handling lines under pressure, and an 

understanding of how working lines behave 

• Follows instructions and response plans 

Note: Each candidate will be evaluated for each element and any deficiencies must be supplemented 

with adequate training and/or experience. 

Additionally, all Level 3 responders must have: 

• Basic Level 3 training, or 

• Advanced Level 3 training - an apprenticeship with PCCS 

LEVEL 4 

Targeted Individuals: Whale researchers and naturalists, fishermen, natural resource agency 

personnel, Marine Patrol Officers. 

Responsibilities 

Level 4 activities- 

• Report, stand by, assess, document, attach a telemetry buoy, consult on an action plan and 

disentangle all large whales except right whales 

• Report, stand by, assess, document and attach a telemetry buoy to right whales 

• On a case by case basis and after consultation (see commitment to consult under Level 5 

below), certain cuts on known entangled right whales may be permitted at level 4 if the 

proposed action is first approved by level 5 disentanglers and NMFS
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

NMFS Disentanglement Guidelines February 2009 

5 

Please Note: Entangled whale behavior varies considerably by species. However, Level 4 

Disentanglers should routinely be able to attempt disentanglement of all large whales other than right 

whales. 

Criteria for certification 

Basic or Advanced Level 3 Certification and: 

• Direct experience in a supervised (by PCCS/Network coordinators or NMFS) large whale 

disentanglement, documentation of that experience, and a positive evaluation from NMFS 

using information provided by PCCS/Network Coordinators and any hard documentation (i.e.

video) 

• When possible, commitment to consultation as detailed in Level 5 below 

LEVEL 5 

Targeted Individuals: Level 4 Responders 

Responsibilities 

Level 5 activities - report, stand by, assess, document, attach a telemetry buoy, consult on an action 

plan and disentangle all large whales including right whales. 

Please Note: Right whales are aggressive and therefore generally the most difficult whales to 

disentangle. North Atlantic right whales are among the most critically endangered large whales in the 

world. Certification at this level is highly selective and specialized. 

Criteria for certification 

Level 4 certification and: 

• Experience w/ right whale behavior and/or includes a person on the team directly involved in 

the whale disentanglement (in the boat with the whale) that is experienced in right whale 

behavior 

• Documented participation in a right whale disentanglement and/or NMFS/PCCS review of 

video of participation in a right whale disentanglement that followed NMFS protocol 

• Commitment to Consultation to include: 
Policies and Best Practices for Marine Mammal Response, Rehabilitation, and Release 

NMFS Disentanglement Guidelines February 2009 

6 

o Immediate Consultation: when possible, use satellite/cell phones to bring in 

additional ideas/experience from other level 5s and level 4s (and vets and 

behaviorists if appropriate) while on scene with an entangled right whale 

o Action Plan Development: For a tagged right whale, consultation required with 

NMFS, level 5s and 4s, veterinarians, behaviorists, etc. 

Rationale for consultation: First assessments and strategies almost invariably change with more 

discussion or information. Consultation will likely help to increase human safety and critical choices 

regarding risks to whale health must be made with the best available information. 
1

Best Practices for Marine Mammal Response, 

Rehabilitation, and Release 

Glossary of Terms 

Animal Care Supervisor– Responsible for overseeing prescribed treatments, maintaining hospital 

equipment, and controlling drug supplies. The person should be adequately trained to deal with 

emergencies until the veterinarian arrives, be able to direct the restraint of the animals, be responsible 

for administration of post-surgical care, and be skilled in maintaining appropriate medical records. It 

is important that the animal care supervisor should communicate frequently and directly with the 

attending veterinarian to ensure that there is a timely transfer of accurate information about medical 

issues. 

Assessment Team – The team of individuals who collectively assess the rehabilitation case and make 

a release determination recommendation. This team could include the attending veterinarian, lead 

animal care supervisor, and/or consulting biologist with knowledge of species behavior and life 

history). 

Attending Veterinarian - U.S. licensed veterinarian [i.e., graduated from a veterinary school 

accredited by the American Veterinary Medical Association Council on Education, or has a certificate 

by the American Veterinary Graduates Association’s Education Commission for Foreign Veterinary 

Graduates or has received equivalent formal education as determined by NMFS Administrator 

(adapted from the Animal Welfare Act Regulations 9 CFR Ch. 1)] who has the responsibility to 

oversee veterinary medical aspects of live animal care and is also responsible for assuring the health 

of marine mammals released back to the wild following rehabilitation.

Authorized Representative- Individual with signatory authority for the stranding organization. This 

individual may be the signatory of the stranding agreement (e.g., Executive Director, President, CEO, 

etc.). 

Bite - An injury from an animal that results in a break in the skin (epidermis). 

Cohorts- Belonging to same species.

Conspecifics- Belonging to same species. 
2

Diseases of Public Health and Safety Concern- Diseases that have been identified by Federal and 

State agencies (e.g., Centers for Disease Control and Prevention and state public health agencies) that 

pose a significant risk to public health. 

Diseases of Zoonotic Concern- Diseases that are transmitted from animals to humans. 

Ecological Status- A concept to consider when making release determinations. This concept 

attempts to integrate the medical and behavioral evaluations into an extrapolation of how the animal 

would likely do in the wild when exposed to typical ecological pressures

Emerging Diseases- Newly recognized serious disease, the cause of which may or may not yet be 

established, that has the potential to spread within and between populations. 

Epidemic (adjective)- Affecting or tending to affect an atypically large number of individuals within 

a population, community, or region at the same time. 

Epizootic (noun)- An outbreak of disease affecting many animals of one kind at the same time 

(similar to epidemic and term typically used in for animals) 

ESA- Endangered Species Act 

Ethogram- A catalogue of the discrete behaviors typically employed by a species. These behaviors 

are sufficiently stereotyped that an observer may record the number of such acts, or the amount of 

time engaged in the behaviors in a period of time. 

FWC – Florida Fish and Wildlife Conservation Commission 

FWS (U.S. Fish and Wildlife Service) - The mission of the U.S. Fish and Wildlife Service is 

working with others to conserve, protect and enhance fish, wildlife, and plants and their habitats for 

the continuing benefit of the American people. 

FWS Division of Management Authority (DMA)- The Division of Management Authority 

implements domestic laws and international treaties to promote long term conservation of global fish 

and wildlife resources. In response to ever-increasing global pressures of wildlife trade and habitat 

loss on species worldwide, the office dedicates its efforts to conserving species at risk through trade 

and implementing policies that have a broad impact on conservation overall.
3

FWS Field Offices- The program operations of the FWS are performed at various types of field 

installations within FWS Regional Offices. The FWS Field Offices that are involved with health and 

stranding of marine mammals under jurisdiction of the FWS are identified in Appendix H.

FWS Letter of Authorization (LOA) - LOAs are issued by the FWS Division of Management to 

authorize under a “permit” network individuals, facilities, and agencies to rescue, rehabilitate, and 

release species under their jurisdiction that are in need of assistance. Authorizations and requirements 

are specific to the species, the organization, and the activity being conducted. 

Humane Care- Treatment of an animal in such a way to both minimize pain and suffering and (by 

providing for proper care and use of the animal) to maximize well being of the individual and the 

population into which it is to be released. 

Human Interaction- Physical signs or evidence (e.g., wounds, marks, gear, etc.) of direct human 

associated interaction that may or may not be related to the stranding. 

Key Personnel – Individuals who represent the stranding organization and serve in key positions 

such as the authorized representative, primary responder, animal care supervisor, and attending 

veterinarian. 

Letter of Concurrence from the NMFS Regional Administrator (RA) - The official notification 

from the NMFS regional office that concurs with the release determination recommendation. 

Letter of Intent- A letter from a prospective permanent care facility requesting custody of a nonreleasable animal. This letter must be sent to the NMFS Office of Protected Resources, Permits, 

Conservation and Education Division (http://www.nmfs.noaa.gov/pr/permits/mmpa_permits.htm). 

MMPA- Marine Mammal Protection Act 

MMPA/ESA Permit No. 932-1489-09- A permit issued by the NMFS Office of Protected Resources, 

Permits, Conservation and Education Division to the Marine Mammal Health and Stranding 

Response Program (MMHSRP). The permit covers some of the MMHSRP’s activities, including 

emergency response activities for threatened and endangered species, large whale disentanglement 

activities, health assessment studies, and other research projects. 

Marine Mammal Unusual Mortality Event- A stranding that is unexpected, involves a significant 

die-off of any marine mammal population, and demands immediate response. 
4

Necropsy Team Leader- A NMFS approved team leader, responsible for all aspects of the necropsy. 

The Necropsy Team Leader assigns task during the necropsy and is responsible for the gross report 

and final necropsy report.

NMFS- National Marine Fisheries Service 

NMFS National Stranding Coordinator- Develops national policy and guidance and oversees the 

national marine mammal stranding program (part of the NMFS Marine Mammal Health and 

Stranding Response Program) 

NMFS Office Director- Office Director for the National Marine Fisheries Service, Office of 

Protected Resources 

NMFS PR1- NMFS Office of Protected Resources, Permits, Conservation and Education Division 

NMFS Regional Director- Regional Administrator for the National Marine Fisheries Service 

Regional Office (regional specific) 

NMFS Regional Stranding Coordinator- Coordinates administration of the stranding program 

within the region. 

NMFS Stranding Agreement- The official written agreement between NMFS and Stranding 

Network Participant as allowed under section 112(c) of the Marine Mammal Protection Act. 

Primary Responder – Oversees all aspects of each stranding response and be on-site or supervising 

when live or dead animals are being examined or handled (i.e., paid staff and unpaid staff). If 

working with live animals, be in direct contact with the attending veterinarian if necessary. 

Panmictic- Referring to unstructured populations (random mating). 

Pre-Release Health Screen- Required to be completed prior to release of animals following 

rehabilitation in accordance with these guidelines 

Reasonable Social Group- Refers to in association with conspecifics of similar age, sex, and/or 

relatedness as would be found in social groups observed in the wild.
5

Release Determination Recommendation- The official written recommendation for release or non 

release signed by the attending veterinarian and signatory rehabilitation facility and sent to the NMFS 

Regional Director. 

Release Plan- If release is recommended and NMFS concurs, the release plan will include a timeline, 

release site, method of transport and tagging/post release monitoring. Conditional releases will 

require an expanded release plan including a justification and detailed description of the logistics, 

tagging, location, timing, crowd control, media coordination (if applicable), and post release 

monitoring. NMFS may require contingency plans, should the release be unsuccessful, including 

recapture of the animal following a specified time after release. 

Reportable Diseases- Diseases that pose a significant concern to public health, agriculture, and 

marine mammal populations and are required to be reported to NMFS and state agencies. 

Responsible Party of Record- This is the official who has the legal authority to make acquisition 

and disposition decisions on behalf of an organization, institution, or agency that is holding marine 

mammals in captivity. This person’s signature is required on the Letter of Intent to permanently 

retain or acquire a nonreleasable animal.

Signatory- The individual who signed the official stranding agreement between the stranding 

organization and NMFS (e.g., Executive Director, President, CEO). 

Stranding Network Participant - A nongovernmental entity authorized by an agreement (Stranding 

Agreement) with NMFS to respond to stranded marine mammals under section 112(c) of the Marine 

Mammal Protection Act, which provides special exemption from the take prohibition. 

Sub Designee- An entity acting under the authority and oversight of the Stranding Network 

Participant.

Surveillance Program- A method of surveillance that generates a source of information on the 

animal health status of populations. 

Transfer Authorization Letter- The letter issued by NMFS PR1 to the receiving facility which 

authorizes retention or acquisition of a marine mammal that has been deemed nonreleasable. 

USGS – United States Geological Survey 
6

Working Group on Marine Mammal Unusual Mortality Events- An official panel of scientific 

experts established by the Marine Mammal Protection Act to who advise the NMFS and FWS 

regarding unusual mortality events. 

109(h) Stranding Participant- State or local government official who can respond to a stranded 

marine mammal for the protection or welfare of the marine mammal and protection of public health 

and welfare during the course of their official duties. Section 109(h) of the Marine Mammal 

Protection Act provides special exemption from the take prohibition. 

Zoonotic- Diseases caused by infectious agents that can be transmitted between (or are shared by) 

animals and humans. 
APPENDIX D 

SCOPING REPORT- MARCH 2006 

National Marine Fisheries Service 

Office of Protected Resources 

1315 East-West Highway 

Silver Spring, MD 20910 

Marine Mammal Health and 

Stranding Response Program 

Environmental Impact Statement 

Scoping Report 

March 2006 

Photo by NMFS NWR 

Photo by Lynne Barre, NMFS 

Photo by Provincetown Center for Coastal Studies 
Marine Mammal Health and Stranding Response Program 

ACRONYMS 

CFR Code of Federal Regulations 

EIS Environmental Impact Statement 

ESA Endangered Species Act 

MMHSRP Marine Mammal Health and Stranding Response Program 

MMPA Marine Mammal Protection Act 

NEPA National Environmental Policy Act 

NMFS National Marine Fisheries Service 

NOI Notice of Intent 

NOAA National Oceanic and Atmospheric Administration 

OSP Optimal Sustainable Population 

SA Stranding Agreement 

UME Unusual Mortality Event 

Scoping Report March 2006 

i
Marine Mammal Health and Stranding Response Program 

SCOPING REPORT FOR THE 

MARINE MAMMAL HEALTH AND STRANDING RESPONSE PROGRAM 

ENVIRONMENTAL IMPACT STATEMENT

TABLE OF CONTENTS

SECTION PAGE

1. Introduction...............................................................................................................1 

1.1 EIS Background Information......................................................................................1 

1.2 Purpose of Scoping....................................................................................................2 

2. Scoping Meetings Summary.....................................................................................2 

2.1 Public Notices...........................................................................................................2 

2.2 Newspaper Announcements of Public Notice ..............................................................2 

2.3 Information Repositories............................................................................................3 

2.4 Public Scoping Meetings............................................................................................3 

3. Scoping Comments....................................................................................................4 

3.1 EIS Comments..........................................................................................................4 

3.2 Interim Policies and Best Practices Comments.............................................................8 

4. Conclusion ...............................................................................................................10 

 

APPENDICES

A Federal Register Notice of Intent- December 28, 2005 

B Informational Fact Sheets from Public Scoping Meetings 

C Public Scoping Meeting Transcripts, January 24- February 17, 2006 

D Comments Received During Scoping Process 

TABLES

1. Public Scoping Meeting Information................................................................................... 4 

Scoping Report March 2006 

ii
Marine Mammal Health and Stranding Response Program 

1. Introduction 

The National Marine Fisheries Service (NMFS) published a Notice of Intent (NOI) in the Federal 

Register on December 28, 2005 (Appendix A). The NOI announced NMFS’ decision to prepare an 

Environmental Impact Statement (EIS) on the activities of the Marine Mammal Health and Stranding 

Response Program (MMHSRP) and conduct public scoping meetings. The EIS is being prepared in 

accordance with the National Environmental Policy Act (NEPA). The NOI began the official scoping 

process for the EIS. This document summarizes the scoping process and the comments received 

during the process. 

1.1 EIS Background Information 

NMFS coordinates and operates the MMHSRP for response to stranded marine mammals and 

research on marine mammal health, pursuant to Title IV of the Marine Mammal Protection Act 

(MMPA; 16 U.S.C. 1421). Marine mammal stranding response is primarily conducted by a network 

of volunteer organizations across the country that are government officials under the authority of 

§109(h) or other groups that have entered into a Stranding Agreement or Letter of Agreement (SA or 

LOA) with NMFS pursuant to §112(c) of the MMPA. The MMHSRP operates at the national and 

regional level to coordinate and facilitate these responses. 

To provide further guidance to marine mammal stranding network members and to nationally 

standardize the guidelines and protocols of participants in the stranding network, NMFS has 

developed several policy documents that are collectively named the Policies and Best Practices for 

Marine Mammal Stranding Response, Rehabilitation and Release. These documents are currently 

issued on an interim basis, and the MMHSRP is proposing to issue them in final after the NEPA 

analysis is concluded. 

Some activities of the MMHSRP are conducted under a permit issued under the MMPA and Section 

10(a)(1)(A) of the Endangered Species Act (ESA) by the Permits, Conservation, and Education 

Division of the NMFS Office of Protected Resources. The permit covers stranding and emergency 

response activities (including disentanglement) for endangered marine mammal species, health 

assessment studies, and a variety of other research projects. 

The current MMPA/ESA permit expires on June 30, 2007. A NEPA analysis of the activities covered 

under the permit must be completed prior to the issuance of a new permit. A NEPA analysis must 

Scoping Report March 2006 

1
Marine Mammal Health and Stranding Response Program 

also be completed to issue the final version of the Policies and Best Practices for Marine Mammal 

Stranding Response, Rehabilitation and Release manual. 

1.2 Purpose of Scoping 

NEPA defines scoping as an “early and open process for determining the scope of issues to be 

addressed and for identifying the significant issues related to a proposed action” (40 CFR 1501.7). 

NMFS is required by NEPA to include scoping as part of the EIS process. The scoping meetings 

provided NMFS the opportunity to inform the public regarding the MMHSRP’s EIS and to obtain 

pubic input on the range of issues to be covered in the EIS. Comments were also collected via e-mail, 

postal mail and fax during the scoping process. 

2. Scoping Meetings Summary 

2.1 Public Notices 

Announcements for the dates and locations of scoping meetings were sent to 253 entities, including 

federal and state government agencies, Alaska natives, Native American tribes, and nongovernmental organizations. In addition, a total of 160 packets with the scoping meeting information 

and additional background documentation were sent to marine mammal stranding network members, 

marine mammal disentanglement network members, and MMPA/ESA research permit coinvestigators. 

Meeting announcements were sent to the email list for the Northeast, Southeast, and Southwest 

Regional stranding networks. An announcement was also sent to the MARMAM list-serve, an edited 

e-mail discussion list focusing on marine mammal research and conservation. The scoping meeting 

schedule was also available on the MMHSRP website at http://www.nmfs.noaa.gov/pr/health/eis.htm. 

2.2 Newspaper Announcements of Public Notice 

Public notices announcing the scoping meetings were published in a newspaper in each of the 

meeting locations. The notices were published one week before the meeting date. Each notice 

included the date, time, and location of the meeting, and where additional information on the EIS 

could be obtained. The newspapers and dates the announcements were published are listed below: 

• Santa Barbara News-Press: January 17, 2006 

• The San Francisco Examiner: January 18, 2006 

Scoping Report March 2006 

2
Marine Mammal Health and Stranding Response Program 

• The Honolulu Advertiser: January 20, 2006 

• The Seattle Times: January 23, 2006 

• Anchorage Daily News: January 25, 2006 

• St. Petersburg Times: January 31, 2006 

• The Boston Globe: February 6, 2006 

• The Washington Post: February 10, 2006 

2.3 Information Repositories 

Information on the MMHSRP and the EIS was available at a public library in each of the scoping 

meeting locations. Information was also available on the MMHSRP website. Information included 

the interim draft of the Best Practices and Policies Manual; the NOI; and handouts summarizing the 

MMHSRP, the EIS Process, and the Proposed Action and Alternatives. 

2.4 Public Scoping Meetings 

Eight public scoping meetings were held in January and February of 2006. Meeting locations were 

chosen in each of the six NMFS regions: Alaska, Northeast, Northwest, Southeast, Southwest (two 

meetings), and the Pacific Islands. A meeting was also held at the National Oceanic and Atmospheric 

Administration (NOAA) Headquarters in Silver Spring, Maryland. Table 1 lists the meeting 

locations, date, time, number of attendees, and the number of oral comments received. The number 

of attendees is an approximation, as not all attendees signed in at the meeting. The number of 

attendees also includes the NMFS regional stranding coordinators, when applicable. 

At the entrance to each meeting, attendees were encouraged to sign the registration sheet. Attendees 

could sign up to present oral comments or to be placed on the EIS mailing list. Written comment 

forms, the NOI, and handouts with information on the EIS and MMHSRP were also available at the 

entrance (see Appendix B). 

The meetings consisted of a poster session, a formal presentation by NMFS personnel, an oral 

comment period, and an informal question and answer session. The poster session allowed the public 

to ask NMFS personnel questions before the meeting. The formal presentation provided the audience 

with information on NEPA, the EIS process, the MMHSRP, and the alternatives under consideration. 

The oral comment period provided attendees the opportunity to make a formal statement. The 

informal question and answer period allowed attendees to ask questions about information provided 

Scoping Report March 2006 

3
Marine Mammal Health and Stranding Response Program 

in the presentation. Each meeting was captured by a court reporter for an accurate public record (the 

informal question and answer session was not recorded). Official transcripts from each meeting are 

in Appendix C. Written comments were also accepted at the meeting. Attendees were informed that 

NMFS would accept written comments until February 28, 2006. 

Table 1. Public Scoping Meeting Information 

Location Date/Time 

Number 

of 

Attendees 

Number 

of Oral 

Comments 

Santa Barbara, CA

Santa Barbara Natural History Museum 

January 24, 2006 

7:00-10:00 pm 6 1 

San Francisco, CA

Bay Conservation and Development 

Commission 

January 25, 2006 

2:00-5:00 pm 12 2 

Honolulu, HI 

Hawaiian Islands Humpback Whale 

National Marine Sanctuary 

January 27, 2006 

3:00-6:00 pm 7 0 

Seattle, WA 

NMFS Northwest Regional Office

January 30, 2006 

2:00-5:00 pm 15 2 

Anchorage, AK

USFWS Building 

February 1, 2006 

2:00-5:00 pm 12 0 

St. Petersburg, FL 

NMFS Southeast Regional Office

February 7, 2006 

5:00-8:00 pm 20 1 

Boston, MA 

New England Aquarium

February 13, 2006 

5:00-8:00 pm 25 5 

Silver Spring, MD 

Silver Spring Metro Center, Building 4, 

Science Center

February 17, 2006 

2:00-5:00 pm 17 2 

3. Scoping Comments 

During the scoping period (December 28, 2005 to February 28, 2006) 35 comments were collected 

regarding the EIS during public meetings and through e-mail, fax, and mail (Appendix D). 

Comments addressed two specific areas: the EIS and the interim Policies and Best Practices

documents. 

3.1 EIS Comments 

The following is a summary of the types of comments received on the EIS during the scoping 

process: 

Alternatives 

Scoping Report March 2006 

4
Marine Mammal Health and Stranding Response Program 

 General

• Support for the MMHSRP’s Proposed Actions. 

• The No Action, Status Quo, and the activity curtailed immediately alternatives are not 

reasonable alternatives. 

• All stranded marine mammals should be treated equally. 

• Information gained from one species may be applied to another species. 

• Some prioritizing process is needed, due to limited funding. 

• Priority for response (in Alaska) should be based upon factors such as knowledge of the 

species and if the species is involved in a fishery interaction or human consumption. 

• The mandate of the MMPA to protect and conserve marine mammals does not 

discriminate or distinguish among species. 

• Support for the current level of effort under the MMHSRP activities. 

• Status quo alternative does not give enough flexibility to conduct research on stranded 

animals. 

 Response Alternatives

• Support for the alternative to revise and implement stranding agreement (SA) criteria. 

• There should not be different standards of stranding response for different species or 

regions, regardless of status. 

• Standards and levels of responses should be the same regardless of species with the 

exception that endangered and threatened should receive priority in the face of conflicts 

of space or commitment. 

• For initial animal response, the “Response to some animals required, others optional” 

alternative is preferred, but suggest re-wording the alternative and a different 

required/optional breakdown under the alternative. 

 Carcass Disposal/Euthanasia Alternatives 

• Support for the alternative of transporting chemically euthanized animals off-site (other 

animals are left, buried, or transported as feasible). 

• Need to be treated as two separate activities, as disposal of non-euthanized carcasses is 

also an issue. 

• None of the proposed alternatives are optimal, but removal of chemically euthanized 

animals is the best.

Scoping Report March 2006 

5
Marine Mammal Health and Stranding Response Program 

• Unclear whether the “All animals buried on site” and “All animals transported off-site for 

disposal” alternatives refer to all carcasses or only those that have been chemically 

euthanized. Stranding members cannot be responsible for either burial or off-site 

transport of all marine mammal carcasses (without further funding). 

• Euthanasia guidelines are needed for large animals and endangered animals. 

 Rehabilitation Alternatives

• We do not agree with any of the alternatives as written.

• Rehabilitation should be a part of any effective environmental program for the protection 

and conservation of marine mammals. 

• Support for the alternative to modify and implement the rehabilitation facility guidelines.

• Rehabilitation efforts for different populations and/or species might be prioritized based 

on their status. Resources for rehabilitation should be weighted towards species that are 

known to be below the optimal sustainable population (OSP) or towards species for 

which there is insufficient data to accurately assess the population size. Species at or 

above the OSP should receive lower priority, allowing stranding network members to 

choose, based on availability, whether or not they rehabilitate these animals. 

• Unwise to stop requiring rehabilitation of more common species as emerging diseases, 

harmful algal blooms, and other unusual events are more likely to be detected in these 

species.

 Release of Rehabilitated Animals Alternatives

• Support for the alternative to modify and implement the release criteria.

• Agree with “All animals released” alternative if release criteria are adopted as is or with 

minimal changes. However, there may be exceptions when a rehabilitated animal is not 

authorized for release to ensure protection of the environment. 

 Disentanglement Alternatives

• Support for the alternative to implement the disentanglement guidelines and training 

requirements for network participants.

 Biomonitoring and Research Activities Alternatives

• Support for the alternative to issue a new permit with current and new (foreseeable) 

projects.

Scoping Report March 2006 

6
Marine Mammal Health and Stranding Response Program 

MMHSRP Activities 

• Support for the current activities under the MMHSRP. 

• Support for the John H. Prescott Marine Mammal Rescue Assistance Grant Program. 

• More collaboration is needed between researchers and those working with stranded 

animals. 

• Database of stranding response personnel and their experience would be valuable. 

• MMHSRP should focus on the protection of wild populations and not on the recovery of 

single live animals that strand. 

• Suggest the establishment of a central MMHSRP diagnostic laboratory and sample bank 

to alleviate costs to individual centers and provide central data bank for research. 

• Recommend establishing two disentanglement training facilities (one in Provincetown, 

Massachusetts and one on the West Coast) that are accredited to teach the protocols of 

the disentanglement network. 

• Support for a National Disentanglement Coordinator. 

• Need for more trained disentanglement responders with proper gear. 

• Photo documentation of all strandings should be encouraged and guidelines should be 

established for photo and video documentation to facilitate future analysis. 

• Responders collecting Level A stranding data should be properly trained in the collection 

of the data, the importance of the data, and how it will be used by investigators. 

• Level A data forms should incorporate morphological data. May be appropriate to have 

different forms for cetaceans and pinnipeds. 

• Training for response to unusual mortality events (UMEs) needs to be offered to all 

network participants. Network participants should be kept apprised of UMEs in their 

region and nationwide. 

Biological Resources 

• The potential for unintended effects from release of rehabilitated animals that can impact 

wild populations should be considered. 

• Personnel should be trained in animal transport mechanisms to reduce possible animal 

injuries. 

• Toxicity of chemically euthanized carcasses left on beaches may impact scavengers. 

Scoping Report March 2006 

7
Marine Mammal Health and Stranding Response Program 

Coastal Zone Management 

• Personnel need to know the rules/policies for responding on private land, Federal land, 

etc. 

• A consistency determination must be made for federal activities affecting Virginia’s 

coastal resources or uses. 

Human Health and Safety 

• Personnel should be trained in physical environment they will be working in and 

informed about the risk of injuries. 

• Euthanasia solution can be dangerous to personnel. Need to find less toxic solution to 

use. 

• Without the MMHSRP, the general public would likely take matters into their own hands 

in regards to stranded animals. Human health and safety would be at a grave risk without 

the MMHSRP. 

Public Outreach and Education 

• Public education about stranded animals is not well supported in present national 

priorities. This would help reduce the interaction between humans and stranded animals. 

• Funding should be available to stranding network participants to have an educational 

program. 

Treaty Rights 

• The Makah Tribe has the right to stranded animals within their reservation boundaries 

and their Usual and Accustomed areas. 

• Scientific practices and tribal cultural activities on stranded animals can occur at the same 

time. 

3.2 Interim Policies and Best Practices Comments 

The following is a summary of the types of comments received on the interim Policies and Best 

Practices documents during the scoping process: 

General 

• Support for national standards and guidelines for the MMHSRP. 

• Support for issuance of policies and best practices if they are flexible to account for 

species differences and the pressures and conflicts unique to each region. 

Scoping Report March 2006 

8
Marine Mammal Health and Stranding Response Program 

• Policies and practices only address release. 

• Suggest establishing public viewing guidelines that protect animals and visitors. 

• The premier criteria for standards should be the health and welfare of wild populations. 

• Policies seem redundant to requirements instituted by the US Department of Agriculture 

for display of marine mammals and Institutional Animal Care and Use Committees 

requirements. These references could be directly cited to stress where NMFS policies 

may differ or compliment the requirements. 

• It is unclear how the documents work together and the legal status of the documents is 

unclear. 

• How will NMFS enforce these policies? 

• Documents must available to stranding network participants prior to signing SAs. 

• If stranding network participants will be held to strict reporting time frames, NMFS’ 

should agree to do the same. 

• Needs to be a balance so that participating in the stranding program is not overly 

burdensome to institutions. The guidelines being reviewed as part of the EIS process fail 

to achieve a good balance. 

Interim SA Template 

• Agree with conditions described in the template. 

• Concern with Section C, Participant Responsibilities that states that the Participants shall 

bear any and all expenses they incur from activities under the SA. Alaska stranding 

network participants have been provided funding from the NMFS regional office. This 

practice should continue and Alaska should not be aligned with logistics available in 

other regions.

• If the SA is terminated, is there a length of time before the entity can reapply?

Interim Minimum Eligibility Criteria for an SA 

• It is important to recognize the different roles required for response, rehabilitation, and 

release activities. 

• Consideration of requiring letters of recommendation for new and renewing SA 

applicants. 

• The proposed qualifications should be implemented as written. 

• There should be an appeals procedure for those entities denied an SA.

Scoping Report March 2006 

9
Marine Mammal Health and Stranding Response Program 

Interim Rehabilitation Facility Standards 

• Rehabilitation Facility Standards should be minimum standards.

• Providing a designated quarantine building is not feasible. 

• Cost of administering bimonthly diagnostic tests on animals is financially prohibitive and 

staff is not available to administer tests. 

• Standards are standards, the minimal should be removed. 

Interim Standards for the Release of Rehabilitated Marine Mammals 

• Standards do not address immediate release from the beach, or relocation and release 

without entering a rehabilitation facility. 

• More emphasis should be placed on post-release monitoring. 

• Standards are acceptable as written.

Interim Disentanglement Guidelines 

• Support for national disentanglement protocols with respect to safety, documentation, 

reporting, and operations. Some protocols would need to be flexible to tailor them to 

specific circumstances and variable conditions. 

• National standards for the disentanglement network should require that participation and 

advancement at all levels is founded on experience and training. 

• Standards are acceptable as written. 

• The Provincetown Center for Coastal Studies gear and techniques are not necessarily 

applicable in all regions. 

• Clarify why NMFS is liable for injuries or fatalities during disentanglement. 

• Needs to be a process in place for organizational growth and training opportunities need 

to be offered on a regular basis. 

• Divers should be seriously considered in the official protocol for the disentanglement 

network. The protocol should limit diving to disentangle a whale only to those personnel 

who are trained and certified divers. 

4. Conclusion 

NMFS has completed the formal public scoping process for the MMHSRP EIS. The agency will 

consider the comments received, individually and cumulatively, and will address those comments in 

the EIS, to the extent required. Comments received on the interim Policies and Best Practices 

documents will be reviewed and considered during the revision process. Scoping is an iterative 

Scoping Report March 2006 

10
Marine Mammal Health and Stranding Response Program 

process and NMFS will continue to consider all relevant input received throughout the development 

of the EIS. 

Scoping Report March 2006 

11
APPENDIX A 

FEDERAL REGISTER NOTICE OF INTENT

DECEMBER 28, 2005 

Federal Register / Vol. 70, No. 248 / Wednesday, December 28, 2005 / Notices 76777 

5This list of uses is illustrative and provided for 

descriptive purposes only. 

6 ‘‘GIN4 Mo’’ is the proprietary grade of Hitachi 

Metals America, Ltd. 

7‘‘GIN5’’ is the proprietary grade of Hitachi 

Metals America, Ltd. 

8 ‘‘GIN6’’ is the proprietary grade of Hitachi 

Metals America, Ltd. 

scope of this order. These include 

stainless steel strip in coils used in the 

production of textile cutting tools (e.g., 

carpet knives).5 This steel is similar to 

American Iron and Steel Institute (AISI) 

grade 420 but containing, by weight, 0.5 

to 0.7 percent of molybdenum. The steel 

also contains, by weight, carbon of 

between 1.0 and 1.1 percent, sulfur of 

0.020 percent or less, and includes 

between 0.20 and 0.30 percent copper 

and between 0.20 and 0.50 percent 

cobalt. This steel is sold under 

proprietary names such as ‘‘GIN4 Mo.’’6

The second excluded stainless steel 

strip in coils is similar to AISI 420–J2 

and contains, by weight, carbon of 

between 0.62 and 0.70 percent, silicon 

of between 0.20 and 0.50 percent, 

manganese of between 0.45 and 0.80 

percent, phosphorus of no more than 

0.025 percent and sulfur of no more 

than 0.020 percent. This steel has a 

carbide density on average of 100 

carbide particles per 100 square 

microns. An example of this product is 

‘‘GIN5’’7 steel. The third specialty steel 

has a chemical composition similar to 

AISI 420 F, with carbon of between 0.37 

and 0.43 percent, molybdenum of 

between 1.15 and 1.35 percent, but 

lower manganese of between 0.20 and 

0.80 percent, phosphorus of no more 

than 0.025 percent, silicon of between 

0.20 and 0.50 percent, and sulfur of no 

more than 0.020 percent. This product 

is supplied with a hardness of more 

than Hv 500 guaranteed after customer 

processing, and is supplied as, for 

example, ‘‘GIN6.’’8

Rescission of Review 

The applicable regulation, 19 CFR 

351.213(d)(1), states that if a party that 

requested an administrative review 

withdraws the request within 90 days of 

the publication of the notice of the 

initiation of the requested review, the 

Secretary will rescind the review. It 

further states that the Secretary may 

extend this time limit if the Secretary 

finds it reasonable to do so. As noted 

above, three of the five petitioners that 

requested this review timely withdrew 

their request for review. On December 1, 

2005, the Department informed counsel 

to petitioners that the instant review 

cannot be rescinded unless all five 

petitioners withdraw their request. See 

Memorandum to the File from Richard 

O. Weible, Office Director, Regarding 

‘‘Phone Conversation with David 

Hartquist,’’ dated December 6, 2005. By 

December 6, 2005, one week after the 

90-day deadline, all five petitioners 

(Allegheny Ludlum Corporation, North 

American Stainless, United Auto 

Workers Local 3303, Zanesville Armco 

Independent Organization, Inc., and the 

United Steelworkers), withdrew their 

request for review. 

The Department finds it reasonable to 

extend the time limit by which a party 

may withdraw its request for review in 

the instant proceeding. The Department 

has not yet devoted considerable time 

and resources to this review, all five 

petitioners have withdrawn their 

request, and no other party requested 

the review. Therefore, we are rescinding 

this review of the antidumping duty 

order on SSSS in coils from Italy 

covering the period July 1, 2004, 

through June 30, 2005. The Department 

will issue appropriate assessment 

instructions directly to U.S. Customs 

and Border Protection within 15 days of 

publication of this notice. 

Notification to Importers 

This notice serves as a final reminder 

to importers of their responsibility 

under 19 CFR 351.402(f) to file a 

certificate regarding the reimbursement 

of antidumping duties prior to 

liquidation of the relevant entries 

during this review period. Failure to 

comply with this requirement could 

result in the Secretary’s assumption that 

reimbursement of antidumping duties 

occurred and subsequent assessment of 

double antidumping duties. 

Notification of Administrative 

Protective Order 

This notice also serves as a reminder 

to parties subject to administrative 

protective order (APO) of their 

responsibility concerning the return on 

destruction of proprietary information 

disclosed under APO in accordance 

with 19 CFR 351.305, which continues 

to govern business proprietary 

information in this segment of the 

proceeding. Timely written notification 

of the return/destruction of APO 

materials or conversation to judicial 

protective order is hereby requested. 

Failure to comply with the regulations 

and terms of an APO is a violation that 

is subject to sanction. 

This notice is issued and published in 

accordance with sections 751 and 777(i) 

of the Act and 19 CFR 351.213(d)(4). 

Dated: December 21, 2005. 

Stephen J. Claeys, 

Deputy Assistant Secretary for Import 

Administration. 

[FR Doc. E5–7984 Filed 12–27–05; 8:45 am] 

BILLING CODE 3510–05–S 

DEPARTMENT OF COMMERCE 

National Oceanic and Atmospheric 

Administration 

[I.D. 120805B] 

Notice of Intent to Conduct Public 

Scoping Meetings and Prepare an 

Environmental Impact Statement on 

the Activities of the National Marine 

Mammal Health and Stranding 

Response Program 

AGENCY: National Marine Fisheries 

Service (NMFS), National Oceanic and 

Atmospheric Administration (NOAA), 

Commerce. 

ACTION: Notice of Intent to prepare 

environmental impact statement; 

request for comments. 

SUMMARY: The National Marine 

Fisheries Service (NMFS) announces its 

intent to prepare an Environmental 

Impact Statement (EIS) to analyze the 

environmental impacts of the national 

administration of the Marine Mammal 

Health and Stranding Response Program 

(MMHSRP). 

Publication of this notice begins the 

official scoping process that will help 

identify alternatives and determine the 

scope of environmental issues to be 

addressed in the EIS. This notice 

requests public participation in the 

scoping process, provides information 

on how to participate, and identifies a 

set of preliminary alternatives to serve 

as a starting point for discussions. 

ADDRESSES: See SUPPLEMENTARY

INFORMATION for specific dates, times, 

and locations of public scoping 

meetings for this issue. 

FOR FURTHER INFORMATION CONTACT: All 

comments, written statements and 

questions regarding the scoping process, 

NEPA process, and preparation of the 

EIS must be postmarked by February 28, 

2006, and should be mailed to: P. 

Michael Payne, Chief, Marine Mammal 

and Sea Turtle Division, Office of 

Protected Resources, National Marine 

Fisheries Service, 1315 East-West 

Highway, Room 13635, Silver Spring, 

MD 20910–3226, Fax: 301–427–2584 

ATTN: MMHSRP EIS or e-mail at 

mmhsrpeis.comments@noaa.gov with 

the subject line MMHSRP EIS. 

SUPPLEMENTARY INFORMATION: 


wwhite on PROD1PC65 with NOTICES
76778 Federal Register / Vol. 70, No. 248 / Wednesday, December 28, 2005 / Notices 

Background 

NMFS proposes to continue to 

coordinate and operate the National 

Marine Mammal Health and Stranding 

Response Program (MMHSRP) for 

response to stranded marine mammals 

and research into questions related to 

marine mammal health, including 

causes and trends in marine mammal 

health and the causes of strandings, 

pursuant to Title IV of the Marine 

Mammal Protection Act (MMPA; 16 

U.S.C. 1421). Title IV of the MMPA 

established the MMHSRP under NMFS. 

The mandated goals and purposes for 

the program are to: (1) facilitate the 

collection and dissemination of 

reference data on the health of marine 

mammals and health trends of marine 

mammal populations in the wild; (2) 

correlate the health of marine mammals 

and marine mammal populations, in the 

wild, with available data on physical, 

chemical, and biological environmental 

parameters; and (3) coordinate effective 

responses to unusual mortality events 

by establishing a process in the 

Department of Commerce in accordance 

with section 404. 

To meet the goals of the MMPA, the 

MMHSRP carries out several important 

activities, including the National Marine 

Mammal Stranding Network, the John 

H. Prescott Marine Mammal Rescue 

Assistance Grant Program, the Marine 

Mammal Disentanglement Program, the 

Marine Mammal Unusual Mortality 

Event and Emergency Response 

Program, the Marine Mammal 

Biomonitoring Program, the Marine 

Mammal Tissue and Serum Bank 

Program, the Marine Mammal 

Analytical Quality Assurance Program, 

the MMHSRP Information Management 

Program, and the facilitation of several 

regional health assessment programs on 

wild marine mammals. 

A marine mammal is defined as 

‘‘stranded’’ under the MMPA if it is 

dead and on the beach or shore or 

floating in waters under US jurisdiction, 

or alive and on the beach and unable to 

return to the water, in need of medical 

assistance, or out of its natural habitat 

and unable to return to its natural 

habitat without assistance. NMFS is 

currently developing and plans to issue 

national protocols that will help 

standardize the stranding network 

across the country while maintaining 

regional flexibility. These protocols are 

proposed to be issued in one 

consolidated manual, titled Policies and 

Best Practices for Marine Mammal 

Stranding Response, Rehabilitation and 

Release (Policies and Practices). This 

document is currently released on an 

interim basis, and will be available on 

our website after January 9, 2006, at: 

http://www.nmfs.noaa.gov/pr/health/ 

for reference and review. The future 

development of these policies may 

involve issuance of regulations, but 

none are currently proposed. 

Individuals, groups and organizations 

throughout the country have been 

responding to stranded marine 

mammals for decades. After the passage 

of Title IV, NMFS codified the roles and 

responsibilities of participant 

organizations in the National Marine 

Mammal Stranding Network through a 

Letter of Agreement (LOA) or Stranding 

Agreement (SA), issued under MMPA 

section 112(c). By issuing SAs, NMFS 

allows stranding network response 

organizations, acting as ’agents’ of the 

government, an exemption to the 

prohibition on ‘‘takes’’ of marine 

mammals established under the MMPA. 

Federal, state and local government 

officials already have an exemption to 

the take prohibition under section 

109(h) of the MMPA, which allows the 

taking of marine mammals (not listed as 

threatened or endangered) during the 

course of official duties, provided such 

taking is for the protection or welfare of 

the mammal, for public health, or for 

the nonlethal removal of nuisance 

animals. SAs (as conceived) extend the 

same exemption to organizations and 

individuals that are outside of the 

government. 

Stranding Agreements are issued by 

NMFS Regional Administrators, and in 

the past a high level of variability has 

occurred between regions. A 

standardized national template for the 

format of the SA has been developed, 

including sections that may be 

customized by each region in order to 

maintain flexibility. This SA template 

has been subject to public comment on 

several occasions after publication on 

NMFS’ public website and distribution 

to interested parties (most recently on 

Nov. 8, 2004). NMFS has also developed 

a list of minimum criteria for 

organizations wishing to obtain a SA 

and participate in the stranding 

network, and these have also been 

distributed for public comment. These 

criteria differ based on the level of 

involvement of the participant (response 

only; response and transport; 

rehabilitation, etc.). Substantive 

comments received on these documents 

have been either incorporated or 

responded to, if the authors chose not to 

incorporate them. The LOA Template 

and Minimum Eligibility Criteria are the 

first two elements of the ‘‘Policies and 

Practices’’ manual. 

While the MMPA provides an 

exception to the take prohibition for the 

health and welfare of stranded marine 

mammals, no similar exemption is 

contained in the Endangered Species 

Act (ESA). Not all, but many, species of 

marine mammals are listed as 

threatened or endangered under the 

ESA, and are therefore protected by both 

laws. Therefore, the MMHSRP has 

obtained a permit from the Permits, 

Conservation and Education Division of 

the NMFS Office of Protected Resources, 

issued under the MMPA and section 

10(a)(1)(A) of the ESA, to provide the 

necessary exemption to the take 

prohibition where the stranded animal 

in question is listed under the ESA, or 

when response to a stranded animal 

would or could incidentally harass a 

listed species. The permit covers 

stranding and emergency response 

activities, including for example, 

disentanglement, hazing, close 

approaches, and humane euthanasia. 

Captures of wild (presumably healthy) 

animals are also permitted to conduct 

health assessment studies, where such 

activities are part of an investigation 

into a morbidity or mortality issue in 

the wild population, but this is a rare 

occurrence (not routine procedure). 

Stranding network responders are listed 

as co-investigators under this permit. 

The permit also authorizes a variety of 

research projects utilizing stranded 

animals, tissue samples, and marine 

mammal parts for investigations into 

die-offs and other questions regarding 

marine mammal health and stranding. 

The current permit issued to the 

MMHSRP will expire on June 30, 2007, 

and a NEPA analysis of the activities 

covered under the permit must be 

completed prior to the issuance of a new 

permit. This EIS will serve as the NEPA 

analysis of these permitted activities. 

Marine mammals that are undergoing 

rehabilitation, and the facilities that are 

conducting rehabilitation activities, are 

not subject to inspection or review by 

the Animal and Plant Health Inspection 

Service (APHIS) under the United States 

Department of Agriculture, provided 

that they are not also a public display 

facility (separate from their 

rehabilitation activities) or a research 

facility. These facilities are therefore not 

subject to APHIS minimum 

requirements for facilities, husbandry, 

or veterinary standards. NMFS has 

developed minimum standards for 

marine mammal rehabilitation facilities 

that will be required of all facilities 

operating under a SA with NMFS, and 

the interim rehabilitation facility 

standards document is the third element 

of the Policies and Practices manual. 

Section 402 (a) of the MMPA charges 

NMFS with providing ‘‘guidance for 

determining at what point a 

rehabilitated marine mammal is 


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Federal Register / Vol. 70, No. 248 / Wednesday, December 28, 2005 / Notices 76779 

releasable to the wild.’’ Interim 

standards for release of rehabilitated 

marine mammals have been developed 

by NMFS and the US Fish and Wildlife 

Service in consultation with marine 

mammal experts through review and 

public comments, including publication 

in the Federal Register on April 8, 1998 

(63 FR 17156). Three panels of experts 

were also assembled in 2001 to provide 

individual recommendations, which 

have been incorporated into the current 

interim document. These guidelines 

provide an evaluative process for the 

veterinarians and animal husbandry 

staff at rehabilitation facilities to use in 

determining if a stranded marine 

mammal is suitable for release to the 

wild, and under what conditions such a 

release should occur. The interim 

standards are provided in the Policies 

and Practices manual. 

Purpose and Scope of the Action 

NMFS will prepare an EIS to evaluate 

the cumulative impacts of the activities 

of the MMHSRP, including the issuance 

of a final Policies and Procedures 

manual and a new MMPA/ESA permit 

for the program. This EIS will assess the 

likely environmental effects of marine 

mammal health and stranding response 

under a range of alternatives 

characterized by different methods, 

mitigation measures, and level of 

response. In addition, the EIS will 

identify potentially significant direct, 

indirect, and cumulative impacts on 

geology and soils, air quality, water 

quality, other fish and wildlife species 

and their habitat, vegetation, 

socioeconomics and tourism, treaty 

rights and Federal trust responsibilities, 

environmental justice, cultural 

resources, noise, aesthetics, 

transportation, public services, and 

human health and safety, and other 

environmental issues that could occur 

with the implementation of the 

proposed action. For all potentially 

significant impacts, the EIS will identify 

avoidance, minimization and mitigation 

measures to reduce these impacts, 

where feasible, to a level below 

significance. 

Major environmental concerns that 

will be addressed in the EIS include: 

NMFS’ information needs for the 

conservation of marine mammals; the 

types and levels of stranding response 

and rehabilitation activities, including 

level of effort; and the cumulative 

impacts of MMHSRP activities on 

marine mammals and the environment. 

Comments and suggestions are invited 

from all interested parties to ensure that 

the full range of issues related to the 

MMHSRP and its activities are 

identified. NMFS is therefore seeking 

public comments especially in the 

following areas: 

(1) Types of activities. What sort of 

activities in response to stranded marine 

mammals or outbreaks of disease in 

marine mammals should be conducted 

on a national level? Are there critical 

research needs that may be met by 

stranding investigations, rehabilitation, 

biomonitoring, disentanglement, and 

other health-related research activities? 

If so, are these needs currently being 

met? If there are additional needs, what 

are they, how are they likely to benefit 

the marine mammal species, and how 

should they best be met? 

(2) Level of response effort. For 

example, should there be different 

standards or levels of effort for different 

species or groups of species (i.e. 

pinnipeds vs. cetaceans; threatened or 

endangered species vs. increasing 

populations, etc.)? How should NMFS 

set these standards or limits? 

(3) Organization and qualifications. 

How should the national stranding 

network be organized at the local, state, 

regional, eco-system, and national 

levels? How should health assessment 

research be coordinated or organized 

nationally? What should the minimum 

qualifications of an individual or 

organization be prior to becoming an SA 

holder or researcher (utilizing samples 

from stranded animals) to ensure that 

animals are treated successfully, 

humanely, and with the minimum of 

adverse impacts? 

(4) Effects of activities. NMFS will be 

assessing possible effects of the 

activities conducted by, for, and under 

the authorization of the MMHSRP using 

all appropriate available information. 

Anyone having relevant information 

they believe NMFS should consider in 

its analysis should provide a complete 

citation or reference for retrieving the 

information. We seek public input on 

the scope of the required NEPA 

analysis, including th range of 

reasonable alternatives; associated 

impacts of any alternatives on the 

human environment, including geology 

and soils, air quality, water quality, 

other fish and wildlife species and their 

habitat, vegetation, socioeconomics and 

tourism, treaty rights and Federal trust 

responsibilities, environmental justice, 

cultural resources, noise, aesthetics, 

transportation, public services, and 

human health and safety, and suitable 

mitigation measures. We ask that 

comments be as specific as possible. 

Alternatives 

NMFS has identified several 

preliminary alternatives for public 

comment during the scoping period and 

encourage information on additional 

alternatives to consider. Alternative 1, 

the Proposed Action Alternative, would 

result in the publication of the Practices 

and Protocols Handbook and the 

establishment of required minimum 

standards for the national marine 

mammal stranding and disentanglement 

networks. The MMHSRP permit would 

also be issued under this alternative to 

permit response activities for 

endangered species, disentanglement 

activities, biomonitoring projects, other 

research projects conducted by or in 

cooperation with the program, and 

import and export of tissue and other 

diagnostic or research samples. 

Alternative 2, the No Action 

Alternative, would continue the 

activities of the national stranding and 

disentanglement networks without 

issuance of the Policies and Practices. 

No new or renewal Stranding 

Agreements would be issued or 

extended, and the MMHSRP would not 

apply for or receive a new permit. As 

Stranding Agreements with 

organizations expired, the network 

would cease to function. The No Action 

Alternative is required to be included 

for consideration by CEQ regulations. 

Alternative 3 is considered the Status 

Quo alternative and would allow for the 

continuation of the stranding and 

disentanglement networks currently in 

place in the country, and the Policies 

and Practices documents would not be 

issued. However, under the Status Quo 

alternative, Stranding Agreements could 

be renewed or extended (though not 

modified), such that the current level of 

response would continue. No new SAs 

would be issued to facilities that are not 

currently part of the national stranding 

network. This would preclude adaptive 

changes in the stranding network as 

organizations change priorities and wish 

to leave the network, or as new facilities 

are created and wish to become 

involved. The MMHSRP permit could 

be renewed or reissued as written, with 

no modifications. There could be no 

adaptive changes to the research 

protocols as new issues were raised or 

advances made in technology. 

Other alternatives considered by 

NMFS may be eliminated from detailed 

study because they would limit or 

prohibit activities necessary for the 

conservation of the species by NMFS. 

The other alternatives that have been 

considered but may be eliminated from 

further study are: (1) An alternative that 

allows for biomonitoring activities only 

(tissue sampling and study of animals 

caught during targeted health 

assessment projects, subsistence hunts, 

and as incidental bycatch in fishery 

activities only); (2) an alternative that 

allows for a stranding response only (no 


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76780 Federal Register / Vol. 70, No. 248 / Wednesday, December 28, 2005 / Notices 

rehabilitation activities; response to live 

animals would be limited to euthanasia 

or release; no disentanglement or health 

assessment activities; ); (3) an 

alternative that allows for response and 

rehabilitation for cetaceans only; and (4) 

an alternative that allows for response 

and rehabilitation for ESA-listed marine 

mammals only. The elimination of any 

of these activities would impede data 

collection regarding strandings and the 

health of marine mammals that is 

necessary for NMFS conservation and 

recovery efforts for many species. 

In addition to the alternatives listed 

above, NMFS will also utilize the 

scoping process to identify other 

alternatives for consideration. It should 

be noted that although several of the 

listed alternatives would not allow for 

the mandated activities listed in the 

MMPA, under 40 CFR 1506.2(d), 

reasonable alternatives cannot be 

excluded strictly because they are 

inconsistent with Federal or state laws, 

but must still be evaluated in the EIS. 

For additional information about the 

MMHSRP, the national stranding 

network, and related information, please 

visit our website at http:// 

www.nmfs.noaa.gov/pr/health/. 

Public Involvement and Scoping 

Meetings Agenda 

Public scoping meetings will be held 

at the following dates, times, and 

locations: 

1. Tuesday, January 24, 2006, 7 – 10 

p.m., Santa Barbara Natural History 

Museum, 2559 Puesta del Sol, Santa 

Barbara, CA; 

2. Wednesday, January 25, 2006, 2 –

5 p.m.; Bay Conservation and 

Development Commission, 50 California 

Street, Suite 2600, San Francisco, CA; 

3. Friday, January 27, 2006, 3 – 6 

p.m., Hawaiian Islands Humpback 

Whale National Marine Sanctuary O’ahu 

Office, 6600 Kalaniana’ole Highway, 

Honolulu, HI; 

4. Monday, January 30, 2006, 2 – 5 

p.m., NMFS Northwest Regional Office, 

Building 9, 7600 Sand Point Way NE, 

Seattle, WA; 

5. Wednesday, February 1, 2006, 2 –

5 p.m., U.S. Fish and Wildlife Service, 

1011 East Tudor Road, Anchorage, AK; 

6. Tuesday, February 7, 2006, 5 – 8 

p.m., NMFS Southeast Regional Office, 

263 13th Avenue, South, St. Petersburg, 

FL; 

7. Monday, February 13, 2006, 5 – 8 

p.m., New England Aquarium, 

Conference Center, Central Wharf, 

Boston, MA; 

8. Friday, February 17, 2006, 2 – 5 

p.m., Silver Spring Metro Center, 

Building 4, Science Center, 1301 EastWest Highway, Silver Spring, MD. 

Comments will be accepted at these 

meetings as well as during the scoping 

period, and can be mailed to NMFS by 

February 28, 2006 (see FOR FURTHER

INFORMATION CONTACT). 

We will consider all comments 

received during the comment period. 

All hardcopy submissions must be 

unbound, on paper no larger than 8 1/ 

2 by 11 inches (216 by 279 mm), and 

suitable for copying and electronic 

scanning. We request that you include 

in your comments: 

(1) Your name and address; 

(2) Whether or not you would like to 

receive a copy of the Draft EIS (please 

specify electronic or paper format of the 

Draft EIS); and 

(3) Any background documents to 

support your comments as you feel 

necessary. 

All comments and material received, 

including names and addresses, will 

become part of the administrative record 

and may be released to the public. 

Special Accommodations 

These meetings are accessible to 

people with disabilities. Requests for 

sign language interpretation or other 

auxiliary aids should be directed to 

Sarah Howlett or Sarah Wilkin, 301–

713–2322 (voice) or 301–427–2522 (fax), 

at least 5 days before the scheduled 

meeting date. 

P. Michael Payne, 

Chief, Marine Mammal and Sea Turtle 

Division, Office of Protected Resources, 

National Marine Fisheries Service. 

[FR Doc. E5–7990 Filed 12–27–05; 8:45 am] 

BILLING CODE 3510–22–S 

DEPARTMENT OF COMMERCE 

National Oceanic and Atmospheric 

Administration 

[I.D. 122005C] 

Notice of Intent to Prepare an 

Environmental Impact Statement on 

Impacts of Research on Steller Sea 

Lions and Northern Fur Seals 

Throughout Their Range in the United 

States 

AGENCY: National Marine Fisheries 

Service (NMFS), National Oceanic and 

Atmospheric Administration (NOAA), 

Commerce. 

ACTION: Notice of Intent to prepare 

environmental impact statement. 

SUMMARY: The National Marine 

Fisheries Service (NMFS) announces its 

intent to prepare an Environmental 

Impact Statement (EIS) to analyze the 

environmental impacts of administering 

grants and issuing permits associated 

with research on endangered and 

threatened Steller sea lions (Eumetopias 

jubatus) and depleted northern fur seals 

(Callorhinus ursinus). Publication of 

this notice begins the official scoping 

process that will help identify 

alternatives and determine the scope of 

environmental issues to be addressed in 

the EIS. This notice requests public 

participation in the scoping process and 

provides information on how to 

participate. 

The purpose of conducting research 

on threatened and endangered Steller 

sea lions is to promote the recovery of 

the species’ populations such that the 

protections of the Endangered Species 

Act (ESA; 16 U.S.C. 1531 et seq.) are no 

longer needed. Consistent with the 

purpose of the Marine Mammal 

Protection Act (MMPA; 16 U.S.C. 1361 

et seq.), the purpose of conducting 

research on northern fur seals is to 

contribute to the basic knowledge of 

marine mammal biology or ecology and 

to identify, evaluate, or resolve 

conservation problems for this depleted 

species. 

Research on Steller sea lions and 

northern fur seals considered in this EIS 

is funded and permitted by NMFS, 

which are both federal actions requiring 

National Environmental Policy Act 

(NEPA; 42 U.S.C. 4321 et seq.) 

compliance. The need for these actions 

is to facilitate research to: (1) Prevent 

harm and avoid jeopardy or 

disadvantage to the species; (2) promote 

recovery; (3) identify factors limiting the 

population; (4) identify reasonable 

actions to minimize impacts of humaninduced activities; (5) implement 

conservation and management 

measures; and (6) make data and results 

available in a timely manner for 

management of the species. As part of 

this action, NMFS is developing 

measures that will improve efficiency 

and avoid unnecessary redundancy in 

Steller sea lion and northern fur seal 

research, utilize best management 

practices, facilitate adaptive 

management, and standardize research 

protocols. 

ADDRESSES: See SUPPLEMENTARY

INFORMATION for specific dates, times, 

and locations of public scoping 

meetings for this issue. 

FOR FURTHER INFORMATION CONTACT: 

Written statements and questions 

regarding the scoping process must be 

postmarked by February 13, 2006, and 

should be mailed to: Steve Leathery, 

Chief, Permits, Conservation and 

Education Division, Office of Protected 

Resources, National Marine Fisheries 

Service, 1315 East-West Highway, Room 

13705, Silver Spring, MD 20910–3226, 


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APPENDIX B 

INFORMATIONAL FACT SHEETS FROM 

PUBLIC SCOPING MEETINGS

NEPA/EIS FACT SHEET 

The Environmental Impact Statement (EIS) will be prepared in accordance 

with the National Environmental Policy Act (NEPA) of 1969. 

 

What is NEPA? 

The purposes of NEPA are to: 

• Encourage harmony between man and the environment; 

• Promote efforts to prevent or eliminate environmental damage; and 

• Enrich man’s understanding of important ecological systems and natural resources. 

 

NEPA requires that the National Marine Fisheries Service (NMFS): 

• Consider the potential consequences of its decisions (major federal actions) 

on the human environment before deciding to proceed; and 

• Provide opportunities for public involvement, which include: participating in 

scoping, reviewing the Draft and Final EIS, and attending public meetings. 

NEPA does not dictate the decision to be made by NMFS, but informs the 

decision-making process. 

 

What is an EIS? 

An EIS evaluates the actions that a federal agency plans to undertake with respect 

to the potential impacts of these actions on the human environment. The purpose 

of this EIS is to objectively analyze and evaluate the potential impacts on environmental resources from activities conducted under the Marine Mammal Health and 

Stranding Response Program (MMHSRP). 

The EIS will include descriptions of the: 

• Proposed Action 

• Purpose and need for the Proposed Action 

• Alternatives to the Proposed Action 

• Affected environment 

• Environmental consequences of the Proposed Action and alternatives 

• Required mitigation or recommended best management practices (BMPs) 

What environmental resources are normally considered during an EIS?

• Fish and Wildlife 

− Protected Species 

> Threatened and Endangered Species

> Marine Mammals 

> Migratory Birds 

− Non-protected Species 

• Protected and Sensitive Habitats 

− National Marine Sanctuaries 

− Essential Fish Habitat 

− Designated Critical Habitat 

− Vegetation 

• Coastal Zone Management 

• Geology and Soils 

• Air Quality 

• Water Quality 

• Noise 

• Aesthetics 

• Human Health and Safety 

• Socioeconomics and Tourism 

• Public Services 

• Cultural Resources 

• Environmental Justice 

• Treaty Rights 

• Federal Trust Responsibilities 

• Cumulative Impacts 

Opportunities for Public Involvement 

The EIS Process 

Public Outreach/Scoping 

Notice of Intent (NOI) to Prepare EIS 

Published 

Record of Decision 

30-Day Waiting Period 

Notice of Availability of Final EIS 

Published in Federal Register 

Preparation of Final EIS 

Public Information Meetings and 

Comment Period 

Refine Proposed Action 

Preparation of Draft EIS 

Notice of Availability of Draft EIS 

Published in Federal Register 

Photo by NOAA Fisheries 

Photo by Provincetown Center for Coastal Studies 
PUBLIC INPUT 

NMFS is seeking public comments on all issues relating to the MMHSRP, Including the following 

specific questions: 

 

• What sort of activities should be conducted on a local, regional and national level in 

response to stranded, entangled, sick, injured, and other marine mammals in distress? 

 

• Are there critical research or management needs that may be met by stranding investigations, rehabilitation, disentanglement or health-related research and biomonitoring -

activities? Are these needs currently being met? If not. what are they, how are they likely 

to benefit the marine mammal species, and what should be done to meet them? 

 

• Should there be different standards or levels of MMHSRP effort for different species or 

groups of species (i.e. pinnipeds vs. cetaceans; threatened or endangered species vs. 

increasing populations, etc.)? If so, how should NMFS set these standards or priorities? 

 

• Is the current organization of the national stranding and health assessment networks at 

the local, state, regional, ecosystem, and national levels adequate to meet the necessary management and research needs for conservation? If not, what changes should 

be implemented to make the organization more effective? 

 

• What should be the minimum qualifications of an individual or organization prior to becoming a Stranding Agreement holder to ensure that animals are treated appropriately, 

humanely, and with the minimum of 

adverse impacts? 

 

• Are public and animal health and 

safety needs adequately addressed in 

the current organization and operations of the MMHSRP? 

 

• Are there any other relevant issues or 

data NMFS should consider in its 

analysis of activities conducted by, 

for, and under the authorization of the 

MMHSRP? If so, please provide if or a 

reference for it. 

NMFS needs your participation in scoping for the EIS. 

 

What is Scoping? 

Scoping is defined as an “early and open process for determining the scope of issues to be 

addressed and for identifying the significant issues related to a proposed action.” NEPA requires that NMFS include scoping as part of the EIS process. For our scoping, we have chosen 

a combination of public meetings around the country and repositories of the information - 

both virtual (on our website) and real (in a library in each city where a scoping meeting is held). 

Your involvement and input are essential to the EIS 

process. Many opportunities exist to be involved in 

the EIS on the activites of the National Marine Mammal Health and Stranding Response Program 

(MMHSRP): 

• Participate in a scoping meeting 

• Identify specific issues 

• Submit comments 

• Sign up for the mailing list 

• Review and comment on the Draft EIS 

• Participate in a public hearing 

• Review the Final EIS 

 

Information Repository Sites: 

Contacts: 

 

Sarah Howlett or Sarah Wilkin 

Marine Mammal and Sea Turtle Division 

Office of Protected Resources 

NMFS 1315 East-West Highway 

Silver Spring, MD 20910-3226 

Phone: 301-713-2322 

Address your comments by 

February 28, 2006 to: 

 

P. Michael Payne, Chief 

Marine Mammal and Sea Turtle Division 

NMFS 1315 East-West Highway 

Silver Spring, MD 20910-3226 

mmhsrpeis.comments@noaa.gov 

Fax: 301-427-2584 

 

For More Information: 

http://www.nmfs.noaa.gov/pr/health/eis.htm 

 

Scoping Meeting Dates and Locations: 

PLACE DATE 

Santa Barbara, CA 

Natural History Museum 

2559 Puesta del Sol 

Tuesday 

January 24, 2006 

7:00 to 10:00 pm 

San Francisco, CA 

Bay Conservation and 

Development Commission 

50 California Street, Suite 2600 

Wednesday 

January 25, 2006 

2:00 to 5:00 pm 

Honolulu, HI

Hawaiian Islands Humpback Whale 

National Marine Sanctuary 

O`ahu Office 

6600 Kalaniana`ole Highway 

Friday 

January 27, 2006 

3:00 to 6:00 pm 

Seattle, WA 

NMFS Northwest Regional Office 

Building 9 

7600 Sand Point Way NE 

Monday 

January 30, 2006 

2:00 to 5:00 pm 

Anchorage, AK 

U.S. Fish and Wildlife Service 

1011 East Tudor Road 

Wednesday 

February 1, 2006 

2:00 to 5:00 pm 

St. Petersburg, FL 

NMFS Southeast Regional Office 

263 13th Avenue, South 

Tuesday 

February 7, 2006 

5:00 to 8:00 pm 

Boston, MA 

New England Aquarium 

Conference Center 

Central Wharf 

Monday 

February 13, 2006 

5:00 to 8:00 pm 

Silver Spring, MD 

Silver Spring Metro Center, 

Building 4, Science Center 

1301 East-West Highway 

Friday 

February 17, 2006 

2:00 to 5:00 pm 

Santa Barbara Public Library 

40 East Anapamu Street 

Santa Barbara, CA 93101 

San Francisco Public Library 

100 Larkin Street 

San Francisco, CA 94102 

Hawaii State Library 

478 South King Street 

Honolulu, HI 96813 

Seattle Public Library 

1000 4th Avenue 

Seattle, WA 98104 

Z.J. Loussac Public Library 

3600 Denali Street 

Anchorage, AK 99503 

St. Petersburg Public Library 

3745 9th Avenue North 

St. Petersburg, FL 33713 

Boston Public Library 

700 Boylston Street 

Boston, MA 02116 

NOAA Central Library 

1315 East-West Highway 

2nd Floor, SSMC3 

Silver Spring, MD 20910 

Photo by NMFS NWR 

Photo by Lynne Barre, NMFS NWR 
MARINE MAMMAL HEALTH AND 

STRANDING RESPONSE PROGRAM 

 National Marine Mammal Stranding Network 

The National Marine Mammal Stranding Network consists of volunteer stranding networks in all coastal states. These 

networks are authorized through Stranding Agreements with the National Marine Fisheries Service (NMFS) regional 

offices. Network member organizations respond to live and dead stranded marine mammals on the beach, take 

biological samples, transport animals, rehabilitate sick or injured marine mammals and potentially release them 

back to the wild. NMFS oversees, coordinates, and authorizes stranding network activities through one national and 

six regional stranding coordinators. NMFS also provides training to network members. 

 MMHSRP Information Management Program 

The MMHSRP Information Management Program is responsible for the development and maintenance of a variety of 

databases, websites and other tools for disseminating information within the program, Network, and to the public. A 

major recent accomplishment was the rollout of a web-accessible national Level A database for reporting and sharing near-real time stranding data to all regions. The Marine Mammal Tissue Bank inventory will become webaccessible to the public in 2006. Data access policies are being developed to codify protocols for data accuracy, 

quality assurance, and public access to stranding network data. 

 John H. Prescott Marine Mammal Rescue Assistance Grant Program 

The Prescott Grant Program provides grants to eligible stranding network participants and researchers for: 

• Recovery and treatment of stranded marine mammals; 

• Data collection from living or dead stranded marine mammals; and 

• Facility upgrades, operation costs, and staffing needs directly related to the recovery and treatment of stranded 

marine mammals and collection of data from living or dead stranded marine mammals. 

Since the inception of the program in 2001, over $16,000,000 has been disbursed in 187 grant awards. There is an 

annual competitive program as well as funding made available throughout the year for emergency response. 

 Marine Mammal Disentanglement Network 

The Disentanglement Network is a partnership between NMFS, the Provincetown 

Center for Coastal Studies, the U.S. Coast Guard, State agencies, National Marine 

Sanctuaries, and other entities. The Network is responsible for monitoring and 

documenting whales that have become entangled in gear as well as conducting 

rescue operations. The network established protocols for all aspects of response, 

including animal care and assessment, vessel and aircraft support, and media 

and public information. Multiple levels of training are required for animal welfare 

and human safety. Photo courtesy Provincetown Center for Coastal Studies 

 Marine Mammal Health Biomonitoring, Research, Development and Banking Programs 

The MMHSRP coordinates national biomonitoring, research and banking efforts to analyze the health 

and contaminant trends of wild marine mammal populations. The program collects information to 

determine anthropogenic impacts on marine mammals, marine food chains, and marine ecosystems. In addition, the program uses information to analyze the contribution of environmental parameters to wild marine mammal health trends. Finally, the program operates the National 

Marine Mammal Tissue Bank, a joint effort with the National Institute of Standards and Technology, as a long-term repository of samples for future retrospective evaluations. Photo courtesy NIST 

 Marine Mammal Unusual Mortality Event and Emergency Response Program 

The Working Group on Marine Mammal Unusual Mortality Events made up of federal and nonfederal experts from a variety of biological and biomedical disciplines, including federal agency 

representatives, and two international participants from Canada and Mexico. The Working Group 

advises NMFS with regards to marine mammal Unusual Mortality Events (UMEs). The Program coordinates emergency response, investigations into causes of mortality and morbidity, evaluates the 

environmental factors associated with UMEs, provides training and resources as possible, and oversees the Marine Mammal Unusual Mortality Event Fund. 
PROPOSED ACTION & ALTERNATIVES 

No Action Alternative: 

• Allow continuation of stranding and disentanglement networks currently in place. 

• Stranding Agreements (SAs) would not be renewed and new SAs would not be issued. 

• Policies and Practices Manual would not be issued. 

• MMHSRP would not apply for or receive a new permit. 

• As SAs with organizations expired, the national stranding network would cease to function. 

Status Quo Alternative: 

• Allow continuation of stranding and disentanglement networks currently in place. 

• SAs could be renewed or extended, but not modified (current level of response would continue). 

• Policies and Practices Manual would not be issued. 

• No new Stranding Agreements would be issued to facilities not currently part of the national stranding network. 

• MMHSRP permit could be renewed or reissued with no modifications. 

Alternatives 

Purpose and Need 

Purpose: NMFS proposes to continue to coordinate and operate the National Marine Mammal Health and Stranding Response Program (MMHSRP) for response to stranded marine mammals and research into questions related to marine 

mammal health, including causes and trends in marine mammal health and the causes of strandings, pursuant to Title IV 

of the Marine Mammal Protection Act (MMPA; 16 U.S.C. 1421). 

Need: To operate the MMHSRP effectively and efficiently, making the best use of available limited resources; to collect the 

necessary data on marine mammal health and health trends to meet information needs for appropriate conservation 

and management; and to ensure that human and animal health and safety is always a high priority. 

Proposed Action 

• Policies and Best Practices for Marine Mammal Stranding Response, Rehabilitation 

and Release (Policies and Practices) Manual would be issued, establishing required minimum standards for the national marine mammal stranding and disentanglement networks. 

• MMHSRP permit would be issued to permit response activities for endangered species, entanglement activities, biomonitioring projects, and import and export of 

marine mammal tissue samples. 

• Stranding Agreements (formerly LOAs) would continue to be issued or renewed on 

a case-by-case basis as necessary. Photo courtesy Gulfworld Marine Park 

 Biomonitoring Activities Only: 

• Tissue sampling and the study of the health of animals caught during targeted health 

assessment projects, as incidental bycatch in fishery activities, and during subsistence hunting only 

 

 Stranding Response Only: 

• No rehabilitation activities– response to live animals would be limited to euthanasia 

or release. 

• No disentanglement or health assessment activities. 

 

 Response and Rehabilitation for Cetaceans Only 

• No stranding response, rehabilitation, disentanglement, or health assessment activities would 

 be conducted for pinnipeds (seals and sea lions). 

 

 Response and Rehabilitation for Threatened and Endangered Marine Mammals Only 

• No stranding response, rehabilitation, disentanglement, or health assessment 

activities would be conducted for marine mammals not listed as threatened or 

endangered under the Endangered Species Act. 

 

Alternatives Considered That May Be Eliminated From Further Study 

Photo courtesy The Marine Mammal Center 
The Marine Mammal Health and Stranding Response Program Scoping Report 

(March 2006), Appendix C- Public Comments, has been removed to reduce the size 

of the appendices. A summary of the comments can be found in the Scoping 

Report. The entire Scoping Report can be found at the following website: 

http://www.nmfs.noaa.gov/pr/pdfs/health/eis_appendix_d.pdf 
THIS PAGE INTENTIONALLY LEFT BLANK 
APPENDIX E 

BIOLOGICAL RESOURCES TABLES

E-1

Table E-1. Protected and Sensitive Habitats on the U.S. Atlantic Coast 

Protected and Sensitive Habitat Type State/ 

Territory

Acadia National Park NP ME 

Alligator River National Wildlife Refuge NWR NC 

Anagansett National Wildlife Refuge NWR NY 

Archie Carr National Wildlife Refuge NWR FL 

Ashepoo Combahee Edisto Basin National Estuarine Research Reserve NERR SC 

Assateague Island National Seashore NS MD-VA 

Back Bay National Wildlife Refuge NWR VA 

Biscayne National Park NP FL 

Blackbeard Island National Wildlife Refuge NWR GA 

Blackbeard Island Wilderness W GA 

Blackwater National Wildlife Refuge NWR MD 

Block Island National Wildlife Refuge NWR RI 

Bombay Hook National Wildlife Refuge NWR DE 

Brigantine Wilderness W NJ 

Buck Island Reef National Wildlife Refuge NWR VI 

Cabo Rojo National Wildlife Refuge NWR PR 

Canaveral National Seashore NS FL 

Cape Cod Bay Northern Right Whale Critical Habitat CH MA 

Cape Cod National Seashore NS MA 

Cape Hatteras National Seashore NS NC 

Cape Lookout National Seashore NS NC 

Cape May National Wildlife Refuge NWR NJ 

Cape Romain National Wildlife Refuge NWR SC 

Cape Romain Wilderness W SC 

Cedar Island National Wildlife Refuge NWR NC 

Chesapeake Bay (MD) National Estuarine Research Reserve NERR MD 

Chesapeake Bay (VA) National Estuarine Research Reserve NERR VA 

Chincoteague National Wildlife Refuge NWR VA 

Conscience Point National Wildlife Refuge NWR NY 

Crocodile Lake National Wildlife Refuge NWR FL 

Cross Island National Wildlife Refuge NWR ME 

Culebra National Wildlife Refuge NWR PR 

Cumberland Island National Seashore NS GA 

Cumberland Island Wilderness W GA 

Currituck National Wildlife Refuge NWR NC 

Delaware National Estuarine Research Reserve NERR DE 

Desecheo National Wildlife Refuge NWR PR 

Dry Tortugas National Park NP FL 
E-2

Table E-1. Protected and Sensitive Habitats on the U.S. Atlantic Coast (continued) 

Protected and Sensitive Habitat Type State/ 

Territory

E.A. Morton National Wildlife Refuge NWR NY 

E.B. Forsythe National Wildlife Refuge NWR NJ 

Eastern Shore Virginia National Wildlife Refuge NWR VA 

Everglades National Park NP FL 

Fire Island National Seashore NS NY 

Fisherman Island National Wildlife Refuge NWR VA 

Florida Keys National Marine Sanctuary NMS FL 

Florida Keys Wilderness W FL 

Franklin Island National Wildlife Refuge NWR ME 

Gray's Reef National Marine Sanctuary NMS GA 

Great Bay National Estuarine Research Reserve NERR ME 

Great Bay National Wildlife Refuge NWR NH 

Great South Channel Northern Right Whale Critical Habitat CH MA 

Great White Heron National Wildlife Refuge NWR FL 

Green Cay National Wildlife Refuge NWR VI 

Green Sea Turtle Critical Habitat CH PR 

Guana Tolomato Matanzas National Estuarine Research Reserve NERR FL 

Harris Neck National Wildlife Refuge NWR GA 

Hawksbill Sea Turtle Critical Habitat CH PR 

Hobe Sound National Wildlife Refuge NWR FL 

Hudson River National Estuarine Research Reserve NERR NY 

J. H. Chafee National Wildlife Refuge NWR RI 

Jacques Cousteau National Estuarine Research Reserve NERR NJ 

Johnson’s Seagrass Critical Habitat CH FL 

Key West National Wildlife Refuge NWR FL 

Leatherback Sea Turtle Critical Habitat CH VI 

Mackay Island National Wildlife Refuge NWR VA 

Mackay Island National Wildlife Refuge NWR NC 

Marjory Stoneman Douglas Wilderness W FL 

Martin National Wildlife Refuge NWR MD 

Mashpee National Wildlife Refuge NWR MA 

Merritt Island National Wildlife Refuge NWR FL 

Monitor National Marine Sanctuary NMS NC 

Monomoy National Wildlife Refuge NWR MA 

Monomoy Wilderness W MA 

Moosehorn National Wildlife Refuge NWR ME 

Nantucket National Wildlife Refuge NWR MA 

Narragansett Bay National Estuarine Research Reserve NERR RI 
E-3

Table E-1. Protected and Sensitive Habitats on the U.S. Atlantic Coast (continued) 

Protected and Sensitive Habitat Type State/ 

Territory

Navassa Island National Wildlife Refuge NWR PR 

Ninigret National Wildlife Refuge NWR RI 

Nomans Land Island National Wildlife Refuge NWR MA 

North Carolina National Estuarine Research Reserve NERR NC 

North Inlet-Winyah Bay National Estuarine Research Reserve NERR SC 

Oyster Bay National Wildlife Refuge NWR NY 

Parker River National Wildlife Refuge NWR MA 

Pea Island National Wildlife Refuge NWR NC 

Pelican Island National Wildlife Refuge NWR FL 

Pelican Island Wilderness W FL 

Petit Manan National Wildlife Refuge NWR ME 

Pinckney Island National Wildlife Refuge NWR SC 

Piping Plover Critical Habitat CH NC-FL 

Plum Tree Island National Wildlife Refuge NWR VA 

Pond Island National Wildlife Refuge NWR ME 

Prime Hook National Wildlife Refuge NWR DE 

Rachel Carson National Wildlife Refuge NWR ME 

S.B. McKinney National Wildlife Refuge NWR CT 

Sachuest National Wildlife Refuge NWR RI 

Salt River Bay National Historic Park and Ecological Preserve Preserve VI 

Sandy Point National Wildlife Refuge NWR VI 

Sapelo Island National Estuarine Research Reserve NERR GA 

Savannah National Wildlife Refuge NWR SC 

Seal Island National Wildlife Refuge NWR ME 

Seatuck National Wildlife Refuge NWR NY 

Southeastern Right Whale Critical Habitat CH GA-FL 

Stellwagen Bank National Marine Sanctuary NMS MA 

Swanquarter National Wildlife Refuge NWR NC 

Swanquarter Wilderness W NC 

Thatches National Wildlife Refuge NWR MA 

Trustom Pond National Wildlife Refuge NWR RI 

Tybee National Wildlife Refuge NWR SC 

Vieques National Wildlife Refuge NWR PR 

Virgin Islands National Park NP VI 

Waccamaw National Wildlife Refuge NWR SC 

Wallops Island National Wildlife Refuge NWR VA 

Waquoit Bay National Estuarine Research Reserve NERR MA 

Wassaw National Wildlife Refuge NWR GA 
E-4

Table E-1. Protected and Sensitive Habitats on the U.S. Atlantic Coast (continued) 

Protected and Sensitive Habitat Type State/ 

Territory

Wells National Estuarine Research Reserve NERR ME 

Wertheim National Wildlife Refuge NWR NY 

West Indian Manatee Critical Habitat CH FL 

Wolf Island National Wildlife Refuge NWR GA 

Wolf Island Wilderness W GA 

Yellow-shouldered Blackbird Critical Habitat CH PR 

Source: DOC/NOAA and DOI 2006, Wilderness.net 2006 

Notes: CH – Critical Habitat 

NERR – National Estuarine Research Reserve 

NP – National Park 

NS – National Seashore 

NWR – National Wildlife Refuge 

W – Wilderness
E-5

Table E-2. Protected and Sensitive Habitats in the Gulf of Mexico 

Protected and Sensitive Habitat Type State 

Anahuac National Wildlife Refuge NWR TX 

Apalachicola National Estuarine Research Reserve NERR FL 

Aransas National Wildlife Refuge NWR TX 

Bayou Sauvage National Wildlife Refuge NWR LA 

Big Boggy National Wildlife Refuge NWR TX 

Big Branch Marsh National Wildlife Refuge NWR LA 

Bon Secour National Wildlife Refuge NWR AL 

Brazoria National Wildlife Refuge NWR TX 

Breton National Wildlife Refuge NWR LA 

Cedar Keys National Wildlife Refuge NWR FL 

Cedar Keys Wilderness W FL 

Chassahowitzka National Wildlife Refuge NWR FL 

Chassahowitzka Wilderness W FL 

Crystal River National Wildlife Refuge NWR FL 

Delta National Wildlife Refuge NWR LA 

Egmont Key National Wildlife Refuge NWR FL 

Everglades National Park NP FL 

Flower Garden Banks National Marine Sanctuary NMS TX 

Grand Bay National Estuarine Research Reserve NERR AL-MS 

Grand Bay National Wildlife Refuge NWR AL-MS 

Gulf Islands National Seashore NS FL-MS 

Gulf Sturgeon Critical Habitat CH FL-LA 

Island Bay National Wildlife Refuge NWR FL 

Island Bay Wilderness W FL 

J.N. “Ding” Darling National Wildlife Refuge NWR FL 

J.N. “Ding” Darling Wilderness W FL 

Laguna Atascosa National Wildlife Refuge NWR TX 

Lower Suwanee National Wildlife Refuge NWR TX 

Mandalay National Wildlife Refuge NWR LA 

Marjory Stoneman Douglas Wilderness W FL 

Matlacha Pass National Wildlife Refuge NWR FL 

McFaddin National Wildlife Refuge NWR TX 

Mission-Aransas National Estuarine Research Reserve NERR TX 

Moody National Wildlife Refuge NWR TX 

Padre Island National Seashore NS TX 

Passage Key National Wildlife Refuge NWR FL 

Passage Key Wilderness W FL 

Pine Island National Wildlife Refuge NWR FL 
E-6

Table E-2. Protected and Sensitive Habitats in the Gulf of Mexico (continued) 

Protected and Sensitive Habitat Type State 

Pinellas National Wildlife Refuge NWR FL 

Piping Plover Critical Habitat CH FL-TX 

Rookery Bay National Estuarine Research Reserve NERR FL 

Sabine National Wildlife Refuge NWR LA 

San Bernard National Wildlife Refuge NWR TX 

Shell Keys National Wildlife Refuge NWR LA 

St. Marks National Wildlife Refuge NWR FL 

St. Marks Wilderness W FL 

St. Vincent National Wildlife Refuge NWR FL 

Ten Thousand Islands National Wildlife Refuge NWR FL 

Texas Point National Wildlife Refuge NWR TX 

Weeks Bay National Estuarine Research Reserve NERR AL 

West Indian Manatee Critical Habitat CH FL 

Whooping Crane Critical Habitat CH TX 

Source: DOC/NOAA and DOI 2006, Wilderness.net 2006 

Notes: CH – Critical Habitat 

NERR – National Estuarine Research Reserve 

NMS – National Marine Sanctuary 

NP – National Park 

NS – National Seashore 

NWR – National Wildlife Refuge 

W – Wilderness 
E-7

Table E-3. Protected and Sensitive Habitats on the U.S. Pacific Coast 

Protected and Sensitive Habitat Type State 

Admiralty Island National Monument NM AK 

Alaska Maritime National Wildlife Refuge NWR AK 

Alaska Peninsula National Wildlife Refuge NWR AK 

Aleutian Islands Wilderness W AK 

Aniakchak National Monument and Preserve NM AK 

Bandon Marsh National Wildlife Refuge NWR OR 

Becharof National Wildlife Refuge NWR AK 

Becharof Wilderness W AK 

Bogoslof Wilderness W AK 

California Coastal Chinook Salmon ESU Critical Habitat CH CA 

California Coastal National Monument NM CA 

Cape Krusenstern National Monument NM AK 

Cape Meares National Wildlife Refuge NWR OR 

Castle Rock National Wildlife Refuge NWR CA 

Central California Coast Coho Salmon ESU Critical Habitat CH CA 

Central California Steelhead DPS Critical Habitat CH CA 

Central Valley Spring-run Chinook Salmon ESU Critical Habitat CH CA 

Channel Islands National Marine Sanctuary NMS CA 

Chuck River Wilderness W AK 

Chugach National Forest NF AK 

Coastal California Gnatcatcher Critical Habitat CH CA 

Columbia River Chum Salmon ESU Critical Habitat CH OR/WA 

Copalis National Wildlife Refuge NWR WA 

Cordell Bank National Marine Sanctuary NMS CA 

Coronation Island Wilderness W AK 

D.E. San Francisco Bay National Wildlife Refuge NWR CA 

Dungeness National Wildlife Refuge NWR WA 

Elkhorn Slough National Estuarine Research Reserve NERR CA 

Ellicott Slough National Wildlife Refuge NWR CA 

Farallon Wilderness W CA 

Flattery Rocks National Wildlife Refuge NWR WA 

Forrester Island Wilderness W AK 

Glacier Bay National Park NP AK 

Glacier Bay Wilderness W AK 
E-8

Table E-3. Protected and Sensitive Habitats on the U.S. Pacific Coast (continued) 

Protected and Sensitive Habitat Type State 

Grays Harbor National Wildlife Refuge NWR WA 

Guadalupe-Nipomo Dunes National Wildlife Refuge NWR CA 

Gulf of the Farallones National Marine Sanctuary NMS CA 

Hazy Island Wilderness W AK 

Hood Canal Summer-run Chum Salmon ESU Critical Habitat CH WA 

Humboldt Bay National Wildlife Refuge NWR CA 

Izembeck National Wildlife Refuge NWR AK 

Izembeck Wilderness W AK 

Kachemak Bay National Estuarine Research Reserve NERR AK 

Katmai National Park and Reserve NP AK 

Katmai Wilderness W AK 

Kenai Fjords National Park NP AK 

Kenai National Wildlife Refuge NWR AK 

Kenai Wilderness W AK 

Kootzoonoo Wilderness W AK 

Kuiu Wilderness W AK 

Lewis and Clark National Wildlife Refuge NWR OR 

Los Padres National Forest NF CA 

Lower Columbia River Chinook Salmon ESU Critical Habitat CH OR/WA 

Marbled Murrelet Critical Habitat CH AK 

Marin Islands National Wildlife Refuge NWR CA 

Maurille Island Wilderness W AK 

Misty Fjords National Monument NM AK 

Mollie Beattie Wilderness W AK 

Monterey National Marine Sanctuary NMS CA 

Nestucca Bay National Wildlife Refuge NWR OR 

Nisqually National Wildlife Refuge NWR WA 

Northern California Steelhead DPS Critical Habitat CH CA 

North Pacific Right Whale Critical Habitat CH AK 

Nunivak Wilderness W AK 

Olympic Coast National Marine Sanctuary NMS WA 

Olympic National Forest NF WA 

Olympic Wilderness W WA 

Oregon Coast Coho Salmon ESU CH OR 
E-9

Table E-3. Protected and Sensitive Habitats on the U.S. Pacific Coast (continued) 

Protected and Sensitive Habitat Type State 

Oregon Islands National Wildlife Refuge NWR OR 

Oregon Islands Wilderness W OR 

Padilla Bay National Estuarine Research Reserve NERR WA 

Petersburg Creek-Duncan Salt Chuck Wilderness W AK 

Point Reyes National Seashore NS CA 

Protection Island National Wildlife Refuge NWR WA 

Puget Sound Chinook Salmon ESU Critical Habitat CH WA 

Quillayute Needles National Wildlife Refuge NWR WA 

Russell Fjord Wilderness W AK 

Sacramento River Winter-run Chinook Salmon ESU Critical 

Habitat CH CA 

Salinas River National Wildlife Refuge NWR CA 

San Diego National Wildlife Refuge NWR CA 

San Francisco Bay National Estuarine Research Reserve NERR CA 

San Juan Islands National Wildlife Refuge NWR WA 

San Pablo Bay National Wildlife Refuge NWR CA 

Seal Beach National Wildlife Refuge NWR CA 

Semidi Wilderness W AK 

Siletz Bay National Wildlife Refuge NWR OR 

Simeonof Islands Wilderness W AK 

Sinuslaw National Forest NF OR 

South Baranof Wilderness W AK 

South Etolin Wilderness W AK 

South Prince of Wales Wilderness W AK 

South Slough National Estuarine Research Reserve NERR OR 

South-Central California Coast Steelhead ESU Critical Habitat CH CA 

Southern California Steelhead ESU Critical Habitat CH CA 

Southern Oregon/Northern California Coasts Coho Salmon ESU 

Critical Habitat CH CA/OR 

Southern Resident Killer Whale DPS Critical Habitat CH WA 

Spectacled Eider Critical Habitat CH AK 

Steller Sea Lion Conservation Area Conservation 

Area AK 

Steller Sea Lion Critical Habitat CH CA/OR/AK
E-10

Table E-3. Protected and Sensitive Habitats on the U.S. Pacific Coast (continued) 

Protected and Sensitive Habitat Type State 

Steller’s Eider Critical Habitat CH AK 

Stikine-LeConte Wilderness W AK 

Sweetwater Marsh National Wildlife Refuge NWR CA 

Three Arch Rocks National Wildlife Refuge NWR OR 

Tidewater Goby Critical Habitat CH CA 

Tijuana River National Estuarine Research Reserve NERR CA 

Tijuana Slough National Wildlife Refuge NWR CA 

Tebenkof Bay Wilderness W AK 

Togiak National Wildlife Refuge NWR AK 

Tongass National Forest NF AK 

Tracy Arm-Fords Terror Wilderness W AK 

Unimak Wilderness W AK 

Warren Island Wilderness W AK 

Washington Islands Wilderness W WA 

West Chichagof-Yakobi Wilderness W AK 

Western Snowy Plover Critical Habitat CH CA-WA 

Willapa National Wildlife Refuge NWR WA 

Wrangell-St. Elias Wilderness W AK 

Source: DOC/NOAA and DOI 2006, 50 CFR 226.204, 226.205, 226.210, and 226.212, Wilderness.net 2006 

Notes: CH – Critical Habitat 

 DPS – Distinct Population Segment 

 ESU – Evolutionary Significant Unit 

NERR – National Estuarine Research Reserve 

NF – National Forest 

NM – National Monument 

NMS – National Marine Sanctuary 

NP – National Park 

NS – National Seashore 

W – Wilderness 
E-11

Table E-4. Protected and Sensitive Habitats in the Pacific Islands 

Protected and Sensitive Habitat Type State/Territory

Bird Island Marine Sanctuary Marine 

Sanctuary CNMI 

Hawaiian Monk Seal Critical Habitat CH HI 

Fagatele Bay National Marine Sanctuary NMS AS 

Guam National Wildlife Refuge NWR GU 

Hawaiian Islands National Wildlife Refuge NWR HI 

Forbidden Island Marine Sanctuary Marine 

Sanctuary CNMI 

Kilauea Point National Wildlife Refuge NWR HI 

Midway Atoll National Wildlife Refuge NWR HI 

National Park of American Samoa NP AS 

Northwestern Hawaiian Islands Marine National Monument NM HI 

Hawaii Volcanoes Wilderness W HI 

Hawaiian Islands Humpback Whale National Marine Sanctuary NMS HI 

Source: DOC/NOAA and DOI 2006, Wilderness.net 2006 

Notes: AS– American Samoa 

 CH – Critical Habitat 

CNMI– Commonwealth of the Northern Mariana Islands 

GU – Guam 

NM – National Monument 

NMS – National Marine Sanctuary 

NP – National Park 

NWR – National Wildlife Refuge 

W – Wilderness 
E-12

Table E-5. Protected Invertebrates and Plants Inhabiting the Action Area 

Common Name Scientific Name Federal Status 

under ESA 

Action Area 

Occurrence 

Black abalone Haliotis cracherodii E CA 

White abalone Haliotis sorenseni E CA 

Elkhorn coral Acropora palmate T FL, PR, VI 

Staghorn coral Acropora cervicornis T FL, PR, VI 

Johnson’s seagrass Halophila johnsonii T/CH FL 

Source: NMFS 2006, USFWS 2009, 74 FR 1937 

Notes: CH – Critical Habitat 

 E – Federally listed as endangered 

 PR – Puerto Rico 

 T – Federally listed as threatened 

VI – U.S. Virgin Islands 

Table E-6. Sea Turtles Inhabiting the Action Area

Common Name Scientific Name Federal Status 

under ESA Action Area Occurrence 

Green Chelonia mydas T*/CH Entire 

Hawksbill Eretmochelys 

imbricate E/CH South Atlantic Coast, Gulf of Mexico, Pacific Area Islands 

Kemp’s ridley Lepidochelys kempii E Atlantic Coast 

Leatherback Dermochelvs 

coriacea schlegelii E/CH Entire 

Loggerhead Caretta caretta gigas T Entire 

Olive ridley Lepidochelys 

olivacea T 

South Atlantic Coast, 

Pacific Coast (rare in OR, WA, 

AK), Pacific Islands 

Source: USFWS 2009 

Notes: CH – Critical habitat in a ROI 

 E – Federally listed as endangered 

T – Federally listed as threatened 

* – Florida nesting population listed as endangered 

 
E-13

Table E-7. Protected Fisheries Resources on the U.S. Atlantic Coast 

Common Name Scientific Name Federal Status 

under ESA Occurrence 

Atlantic salmon 

(Gulf of Maine DPS) Salmo salar E ME 

Smalltooth sawfish Pristis pectinata E NC-FL 

Shortnose sturgeon Acipenser brevirostrum E Entire Atlantic 

Coast 

Source: USFWS 2009 

Notes: DPS – Distinct Population Segment 

 E – Federally listed as endangered 

Table E-8. Protected Fisheries Resources in the Gulf of Mexico 

Common Name Scientific Name Federal Status 

under ESA Occurrence 

Gulf sturgeon Acipenser oxyrinchus desotoi T/CH FL-LA 

Smalltooth sawfish Pristis pectinata E Entire Gulf of 

Mexico 

Source: USFWS 2009 

Notes: CH – Critical Habitat 

 E – Federally listed as endangered 

 T – Federally listed as threatened 
E-14

Table E-9. Protected Fisheries Resources on the U.S. Pacific Coast 

Common Name Scientific Name Federal Status 

under ESA 

Chinook salmon Oncorhynchus tshawytscha E/T/CH 

California Coastal ESU T/CH 

Central Valley spring-run ESU T/CH 

Lower Columbia River ESU T/CH 

Puget Sound ESU T/CH 

Chinook salmon ESUs: 

Sacramento River winter-run ESU E/CH 

Chum salmon Oncorhynchus keta E/T/CH 

Hood Canal summer-run ESU T/CH 

Chum salmon ESUs: 

Columbia River ESU T/CH 

Coho salmon Oncorhynchus kisutch E/T/CH 

Oregon Coast ESU T/CH 

Southern Oregon/Northern 

California Coasts ESU Coho salmon ESUs: T/CH 

Central California Coast ESU E/CH 

Green sturgeon 

(Southern DPS) Acipenser medirostris T 

Sockeye salmon Oncorhynchus nerka E/T 

Steelhead Oncorhynchus mykiss E/T/CN/CH 

Puget Sound T 

Northern California ESU T/CH

Central California ESU T/CH

South-Central California Coast ESU T/CH

Steelhead ESUs: 

Southern California ESU E/CH 

Tidewater goby Eucyclogobius newberryi E/CH 

Black abalone Haliostis cracherodii E 
E-15

Table E-9. Protected Fisheries Resources on the U.S. Pacific Coast 

(continued) 

Common Name Scientific Name Federal Status 

under ESA 

White abalone Haliostis sorenseni E 

Source: 50 CFR 226.204, 226.205, 226.210, and 226.212, 72 FR 26722, 73 FR 7816 

Notes: CH – Critical habitat 

 CN – Candidate species 

 DPS – Distinct Population Segment 

 E – Federally listed as endangered 

 ESU – Evolutionary Significant Unit 

 T – Federally listed as threatened 

 
E-16

Table E-10. Protected Birds of the U.S. Atlantic Coast 

Common 

Name 

Scientific 

Name 

Federal 

Status 

under 

ESA 

Distribution Migration Pattern 

Bald eagle Haliaeetus 

leucocephalus 

T/AD Locally throughout 

most of North 

America, including 

coasts 

Occurs year-round in many 

coastal areas. Breeds in 

spring, and some 

individuals migrate south 

during winter, while many 

remain in the northeast 

year-round. 

Piping 

plover 

Charadrius 

melodus 

T/CH Atlantic coast, Great 

Lakes, Northern 

Great Plains, Gulf 

coast, and 

Caribbean. Critical 

habitat for wintering 

populations from 

North Carolina 

south to Florida. 

Breeds on sandy beaches in 

isolated colonies on the 

northeast coast and Great 

Lakes region from March 

to September, where they 

spend the summer. 

Winters along southeastern 

coast. 

Roseate 

tern 

Sterna 

dougallii 

dougallii 

E Atlantic coast and 

Caribbean 

Breeds on islands and 

protected sand spits. 

Occurs on northeast coast 

during spring and summer 

and migrates south as far as 

the Caribbean during fall 

and winter. 

Whooping 

crane 

Grus 

Americana 

NEP Virginia to Florida Winters in the Gulf coast 

of Texas October to April, 

when they migrate north to 

Canada. 

Wood 

stork 

Mycteria 

americana 

E South Carolina to 

Florida 

Breeds in Alabama, 

Florida, Georgia, and 

South Carolina. 

Yellowshouldered 

blackbird 

Agelains 

xanthomus 

E/CH Critical habitat areas 

in southwest Puerto 

Rico and Isla Mona 

Resident species in Puerto 

Rico and Isla Mona. 

Nesting season April to 

October. 

Source: USFWS 2009 

Notes: AD – Proposed Delisting 

 CH – Critical Habitat in the ROI 

 E – Federally listed as endangered 

 NEP – Non-essential population 

 T – Federally listed as threatened 
E-17

Table E-11. Protected Birds of the Gulf of Mexico 

Common 

Name 

Scientific 

Name 

Federal 

Status 

under 

ESA 

Distribution Migration Pattern 

Bald eagle Haliaeetus 

leucocephalus 

T/AD Locally throughout 

most of North 

America, including 

coasts 

Winters along central 

and southeast coast and 

Texas coast with yearround populations in 

Florida and Gulf coasts 

east of Texas. 

Brown 

pelican 

Pelecanus 

occidentalis 

E Texas to Mississippi Year-round resident in 

the southeast. 

Piping plover Charadrius 

melodus 

T/CH Atlantic coast, Great 

Lakes, Northern Great 

Plains, Gulf of 

Mexico. Critical 

habitat for wintering 

populations entire 

Gulf Coast. 

Winters on the 

southeast and Gulf 

coasts and the 

Caribbean October to 

March. Breeding: 

Atlantic coast, Great 

Lakes, and Northern 

Great Plains. 

Whooping 

crane 

Grus 

Americana 

E/CH Critical habitat is on 

Texas coast 

Winters in the Gulf 

coast of Texas October 

to April, when they 

migrate north to 

Canada. 

Wood stork Mycteria 

americana 

E Alabama (Mississippi 

Valley) 

Breeds in Alabama, 

Florida, Georgia, and 

South Carolina. 

Source: USFWS 2009 

Notes: AD – Proposed Delisting 

CH – Critical Habitat in the ROI 

 E – Federally listed as endangered 

T – Federally listed as threatened 
E-18

Table E-12. Protected Birds of the U.S. Pacific Coast 

Common 

Name 

Scientific 

Name 

Federal 

Status 

under 

ESA 

Distribution Migration Pattern 

Bald eagle Haliaeetus 

leucocephalus 

T/AD Locally 

throughout most 

of North America, 

including coasts 

Year-round resident and 

breeds in most Pacific 

continental coastal areas. 

Some migration occurs 

from northern California 

and Oregon to southern 

California coast, where 

small population spends 

the summer. 

Brown 

pelican 

Pelecanus 

occidentalis 

E Pacific coast Breeds in southern 

California March to 

April and is found from 

southern Mexico to 

central California and 

occasionally from 

northern California to 

Washington. 

California 

Condor 

Gymnogyps 

californianus

E Condors 

reintroduced into 

mountains of Los 

Angeles, vicinity 

of Big Sur, and 

Arizona 

On coast of California. 

California 

clapper rail 

Rallus 

longirostris 

obsoletus 

E San Francisco Bay 

area, California 

Year-round resident on 

central and southern 

California coast. 

California 

least tern 

Sterna 

antillarum 

browni 

E Central and 

southern coast of 

California 

Breeds and spends 

spring and summer on 

southern and central 

California coasts. 

Migrates to Central 

America and south in 

fall for the winter. 

Coastal 

California 

Gnatcatcher 

Poliioptila 

californica 

californica 

T/CH Southern 

California coast. 

Critical habitat in 

Southern 

California. 

Non-migratory 

inhabiting coastal sage 

scrub from Los Angeles 

county south to Baja 

California, Mexico. 

Light-footed 

clapper rail 

Rallus 

longirostris 

levipes 

E Southern 

California coast 

Year-round resident on 

central and southern 

California coast. 
E-19

Table E-12. Protected Birds of the U.S. Pacific Coast (continued) 

Common 

Name 

Scientific 

Name 

Federal 

Status 

under 

ESA 

Distribution Migration Pattern 

Marbled 

murrelet 

Brachyrampus 

marmoratus 

marmoratus 

T/CH Alaska coast south 

to California 

coast. Critical 

habitat in Alaska. 

Breeds from northern 

Washington to San 

Francisco coast. Winters 

along entire Pacific 

coast. Summers from 

Kenai Peninsula, Barren 

Islands, and Aleutian 

Islands south along the 

coast of North America. 

San Clemente 

loggerhead 

shrike 

Lanius 

ludovicianus 

mearnsi 

E San Clemente 

Island, California 

Year-round resident on 

San Clemente Island. 

San Clemente 

sage sparrow 

Amphispiza belli 

clementeae 

T San Clemente 

Island, California 

Year-round resident on 

San Clemente Island. 

Short-tailed 

albatross 

Phoebastria 

albatrus 

E Open Pacific 

Ocean from 

Alaska to 

California 

Found most commonly 

in summer and fall. 

Breeds in Japan, 

Midway, and Hawaii and 

migrates north for 

summer and south for 

winter. 

Spectacled 

eider 

Somateria 

fisheri 

T/CH Coast of Alaska Breeds on the coast of 

Alaska on the Bering 

Sea and the Arctic 

Ocean. Migrates south 

for the winter but winter 

range is unknown. 

Steller’s eider Polysticta 

stelleri 

T/CH Alaska Coast, 

accidental south to 

California. 

Critical habitat in 

Alaska. 

Accidental in summer in 

Pacific waters. Breeds 

on eastern Arctic coast 

and migrates to Aleutian 

Islands and western 

coast of Alaska. 

Western 

snowy plover 

Charadrius 

alexandrinus 

nivosus 

T/CH Washington to 

California. 

Critical habitat in 

California, 

Oregon, and 

Washington. 

Summers along Pacific 

coast and migrates south 

to Mexico and South 

America during winter. 

Source: USFWS 2009 

Notes: AD – Proposed Delisting 

CH – Critical Habitat in the ROI 

 E – Federally listed as endangered 

 T – Federally listed as threatened 
E-20

Table E-13. Protected Birds of the Pacific Islands 

Common 

Name 

Scientific 

Name 

Federal 

Status 

under 

ESA 

Distribution Migration Pattern 

Guam bridled 

white-eye 

Zosterops 

conspicillatus 

conspicillatus 

E Guam Year-round resident, 

habitat includes beach 

strand. 

Hawaiian Coot Fulica 

americana alai 

E Hawaii coasts Year-round resident 

Hawaiian Islands. 

Hawaiian darkrumped petrel Pterodroma 

phaeopygia 

sandwichensis 

E Pacific Ocean 

around Hawaii 

Found on the 

Hawaiian Islands 

from May to midNovember during 

breeding; central 

Pacific from midNovember through 

April. 

Hawaiian duck Anas wyvilliana E Pearl Harbor, 

Hawaii 

Year-round resident 

on selected Hawaiian 

Islands. 

Hawaiian stilt Himantopus 

mexicanus 

knudseni 

E Hawaii coasts Year-round resident 

Hawaiian Islands. 

Laysan duck Anas 

laysanensis 

E Laysan, Hawaii Year-round resident 

Laysan Atoll, Hawaii. 

Laysan finch Telespyza 

cantans 

E Laysan, Pearl, and 

Hermes atolls, 

Hawaii 

Year-round resident 

Laysan, Pearl, and 

Hermes atolls, 

Hawaii. 

Mariana crow Corvus kubaryii E Guam Year-round resident, 

habitat includes beach 

strand. 

Newell’s 

Townsend’s 

shearwater 

Puffinus 

auricularis 

newelli 

E Pacific Ocean 

around Hawaii 

Found on the island of 

Kauai April through 

September during 

breeding. On the 

open ocean from 

October to April. 

Nihoa finch Telespyza 

ultima 

E Nihoa Island, 

Hawaii 

Year-round resident 

Nihoa Island, Hawaii. 

Short-tailed 

albatross 

Phoebastria 

albatrus 

E Open Pacific 

Ocean from 

Alaska to 

California 

Most common in 

summer and fall. 

Breeds in Midway 

and Hawaii. 

Source: USFWS 2009 

Notes: E – Federally listed as endangered 
E-21

Table E-14. Marine Mammals Common in the NMFS Northeast Region 

Common Name Scientific Name 

Federal 

Status 

under 

ESA 

Distribution 

Phocids (true or earless seals)

Bearded seal Erignathus barbatus * Unusual 

Gray seal Halichoens griseus * Year-round resident 

Harbor seal Phoca vitulina * Year-round resident 

Harp seal Phoca groenlandica * More common in winter 

Hooded seal Cystophora cristata * More common in winter

Ringed seal Phoca hispida * More common in winter

Mysticetes (baleen whales)

Blue whale Balaenoptera 

musculus 

E Population highest in 

spring/summer due to northward 

migration from subtropics 

Bryde’s whale Balaenoptera edeni * Located in southern part of ROI 

Fin whale Balaenoptera 

physalus 

E Year-round resident, peak from 

April to October, visits coastal 

waters in many areas 

Minke whale Balaenoptera. 

acutorostrata

* Abundant from April to 

November; frequent coastal 

regions, bays, offshore banks 

Humpback whale Megaptera 

novaeangliae

E Migratory population, with peak 

abundance mainly during 

summer but also in autumn; 

coastal distribution in the 

summer. Breeds in the 

Caribbean within 8–16 km of 

shore 

North Atlantic 

right whale 

Eubalaena glacialis E/CH Population highest in 

spring/summer 

Sei whale Balaenoptera 

borealis 

E Range from ME to VA 

Odontocetes (toothed whales and dolphins) 

Atlantic whitesided dolphin Lagenorhynchus 

acutus 

* Common inshore spring through 

autumn, uncommon from DE to 

VA 

Atlantic spotted 

dolphin 

Stenella frontalis * Occur in southern part of ROI, 

generally pelagic 

Blainville’s beaked 

whale 

Mesoplodon 

densirostris 

* Pelagic habitat 

Clymene dolphin Stenella clymene * Occur in southern ROI, pelagic 

Cuvier’s beaked 

whale 

Ziphius cavirostris * Common in summer 
E-22

Table E-14. Marine Mammals Common in the NMFS Northeast Region (continued) 

Common Name Scientific Name 

Federal 

Status 

under 

ESA 

Distribution 

Dwarf sperm 

whale 

Kogia sima * Occur from DE to VA 

False killer whale Pseudorca crassidens * Occur from DE to VA 

Gervais’ beaked 

whale 

Mesoplodon 

europaeus 

* Oceanic habitat 

Killer whale Orcinus orca * Occasional visitor 

Long-finned pilot 

whale 

Globicephala melas * Pelagic, moves inshore late 

summer and fall 

Northern 

bottlenose whale 

Hyperoodon 

ampullatus 

* Occasional, seen in fall and 

winter 

Pantropical spotted 

dolphin 

Stenella attenuata * Uncommon 

Pygmy sperm 

whale 

Kogia breviceps * Rare north of Cape Cod, MA 

Risso’s dolphin Grampus griseus * Uncommon north of Cape Cod, 

MA 

Rough-toothed 

dolphin 

Steno bredanensis * Pelagic habitat 

Short-finned pilot 

whale 

Globicephala 

macrorhynchus 

* Generally pelagic, occurs in 

southern ROI (DE to VA) in the 

summer 

Sowerby’s beaked 

whale 

Mesoplodon bidens * Pelagic habitat 

Sperm whale Physeter 

macrocephalus 

E Mainly in deep waters, migrates 

to shallower waters from ME to 

NC 

Spinner dolphin Stenella longirostris * Occurs in southern ROI (DE to 

VA) 

Striped dolphin Stenella coeruleoalba * Common, pelagic habitat 

True’s beaked 

whale 

Mesoplodon mirus * Pelagic habitat 

Beluga whale Delphinapterus leucas * Occasional strays, seen in winter 

Short-beaked 

common dolphin 

Delphinus delphis * Generally pelagic, common 

Bottlenose dolphin Tursiops truncatus * Seen in summer offshore, 

uncommon 

White-beaked 

dolphin 

Lagenorhynchus 

albirostris 

* Occur from November to June 
E-23

Table E-14. Marine Mammals Common in the NMFS Northeast Region (continued) 

Common Name Scientific Name 

Federal 

Status 

under 

ESA 

Distribution 

Harbor porpoise Phocoena phocoena * Common in inshore areas from 

April to October; strandings 

reported in Florida; sometimes 

enters bays and river mouths 

Source: Geraci and Lounsbury 2005 

Notes: CH – Critical Habitat in the ROI 

E – Federally listed as endangered 

T –Federally listed as threatened 

 * – only protected under MMPA 
E-24

Table E-15. Marine Mammals Common in the NMFS Southeast Region 

Common Name Scientific Name 

Federal 

Status 

under ESA 

Distribution 

Phocids (true or earless seals) 

Harbor seal Phoca vitulina * Occasional 

Mysticetes (baleen whales)

Blue whale Balaenoptera 

musculus 

E Population highest in 

spring/summer due to 

northward migration from 

subtropics 

Bryde’s whale Balaenoptera edeni * Common 

Fin whale Balaenoptera 

physalus 

E Year-round resident, visits 

coastal waters in many areas 

Minke whale Balaenoptera 

acutorostrata

* Uncommon in Gulf of Mexico, 

occur in other waters of the 

ROI; frequent coastal regions, 

bays, offshore banks 

Humpback whale Megaptera 

novaeangliae

E Migratory population moves 

along the southeastern U.S. on 

the way to its wintering 

grounds, occur January through 

May 

North Atlantic right 

whale 

Eubalaena glacialis E/CH Wintering and calving grounds 

are along Georgia and Florida, 

occur December through March, 

nearshore 

Sei whale Balaenoptera 

borealis 

E Southern portion of range 

during spring/summer 

Odontocetes (toothed whales and dolphins) 

Atlantic spotted 

dolphin 

Stenella frontalis * Generally pelagic 

Blainville’s beaked 

whale 

Mesoplodon 

densirostris 

* Pelagic 

Bottlenose dolphin Tursiops truncatus * Both coastal and offshore 

variety are common in this ROI, 

frequents bays and estuaries 

Clymene dolphin Stenella clymene * Pelagic 

Cuvier’s beaked 

whale 

Ziphius cavirostris * Pelagic 

Dwarf sperm whale Kogia sima * Pelagic 

Gervais’ beaked 

whale 

Mesoplodon 

europaeus 

* Oceanic 

 
E-25

Table E-15. Marine Mammals Common in the NMFS Southeast Region (continued) 

Common Name Scientific Name 

Federal 

Status 

under ESA 

Distribution 

Harbor porpoise Phocoena phocoena * Rare in southeast Atlantic, not 

in Gulf of Mexico/Caribbean 

False killer whale Pseudorca 

crassidens 

* Pelagic 

Fraser’s dolphin Lagenodelphis hosei * Rare in southeast Atlantic and 

Gulf of Mexico, occurs in 

Caribbean, pelagic 

Killer whale Orcinus orca * Uncommon 

Long-finned pilot 

whale 

Glodicephala melas * Northern part of southeast 

Atlantic, rare, pelagic 

Melon-headed 

whale 

Peponocephala 

electra 

* Rare in southeast Atlantic, occur 

in Gulf of Mexico, pelagic 

Pantropical spotted 

dolphin 

Stenella attenuata * Offshore and coastal groups 

Pygmy killer whale Feresa attenuata * Pelagic 

Pygmy sperm whale Kogia breviceps * Pelagic 

Risso’s dolphin Grampus griseus * Pelagic 

Rough-toothed 

dolphin 

Steno bredanensis * Pelagic 

Short-finned pilot 

whale 

Globicephala 

macrorhynchus 

* Pelagic 

Sperm whale Physeter 

macrocephalus 

E Generally pelagic 

Spinner dolphin Stenella longirostris * Common, pelagic and coastal, 

daytime in shallow bays 

Striped dolphin Stenella 

coeruleoalba 

* Pelagic 

True’s beaked whale Mesoplodon mirus * Pelagic 

Short-beaked 

common dolphin 

Delphinus delphis * Pelagic 

Trichechids (manatees)

West Indian 

manatee 

Trichechus manatus E/CH Resident in rivers and coastal 

waters of peninsular Florida and 

southern Georgia; previous 

records in Carolinas and Texas 

Source: Geraci and Lounsbury 2005 

Notes: CH – Critical Habitat in the ROI 

E – Federally listed as endangered 

* – only protected under MMPA 
E-26

Table E-16. Marine Mammals Common in the NMFS Southwest Region

Common Name Scientific Name 

Federal 

Status 

under ESA 

Distribution 

Otarrids (eared seals or sea lions) 

California sea lion Zalophus 

californianus

* Year-round resident 

Guadalupe fur seal Arctocephalus 

townsendi 

T Breeds off Baja California 

Northern elephant 

seal 

Mirounga 

angustirostris

* Year-round resident 

Northern fur seal Callorhinus 

ursinus

* Year-round resident 

Steller sea lion Eumetopias jubatas T/CH Visitor to area from southern 

breeding grounds, coastal to 

pelagic 

Phocids (true or earless seals) 

Harbor seal Phoca vitulina * Year-round resident 

Mysticetes 

Blue whale Balaenoptera 

musculus 

E Population highest in spring due to 

northward migration from 

subtropics 

Bryde’s whale Balaenoptera edeni * Rare in southern California 

Fin whale Balaenoptera 

physalus 

E Common in summer, visits coastal 

waters in many areas, migratory 

Gray whale Eschrichtius 

robustus

* Migration population, with peak 

abundance in winter and spring 

Humpback whale Megaptera 

novaeangliae

E Migratory population, with peak 

abundance mainly during summer 

but also in autumn 

Minke whale Balaenoptera 

acutorostrata

* Year-round resident, frequent 

coastal regions, bays, offshore 

banks 

North Pacific right 

whale 

Eubalaena 

japonica 

E Only two sightings in southern 

California 

Sei whale Balaenoptera 

borealis 

E Seen in summer/fall during 

migration, pelagic 

Odontocetes (toothed whales and dolphins) 

Baird’s beaked 

whale 

Berardius bairdii * Peak June-October, pelagic 

Blainville’s beaked 

whale 

Mesoplodon 

densirostris 

* Pelagic 

Bottlenose dolphin Tursiops truncatus * Year-round resident; frequents 

bays and estuaries in southern 

regions 
E-27

Table E-16. Marine Mammals Common in the NMFS Southwest Region (continued)

Common Name Scientific Name 

Federal 

Status 

under ESA 

Distribution 

Cuvier’s beaked 

whale 

Ziphius cavirostris * Pelagic 

Dall’s porpoise Phocoenoides dalli * Year-round resident, nearshore in 

deep water, pelagic 

Dwarf sperm 

whale 

Kogia sima * Rare further north, pelagic 

Ginkgo-toothed 

beaked whale 

Mesoplodon 

ginkgodens 

* Rare, pelagic 

False killer whale Pseudorca 

crassidens 

* Occasional, pelagic 

Harbor porpoise Phocoena 

phocoena

* Coastal in bays, estuaries, and 

rivers; frequent offshore banks 

Hubb’s beaked 

whale 

Mesoplodon 

carlhubbsi 

* Pelagic 

Killer whale Orcinus orca * Incidental accounts of transients in 

area, most likely from northern 

latitudes; common inshore visitors 

Long-beaked 

common dolphin 

Delphinus capensis * Occur in southern California, 

prefer shallow, warm waters 

Northern right 

whale dolphin 

Lissodelphis 

borealis 

* Inshore winter through spring, 

pelagic 

Pacific white-sided 

dolphin 

Lagenorhynchus 

obliquidens

* Year-round resident, peak winter 

through spring, pelagic 

Perrin’s beaked 

whale 

Mesoplodon perrini * Pelagic 

Pygmy sperm 

whale 

Kogia breviceps * Pelagic 

Risso’s dolphin Grampus griseus * Year-round resident, pelagic 

Rough-toothed 

dolphin 

Steno bredanensis * Uncommon, pelagic 

Short-beaked 

common dolphin 

Delphinus delphis * Year-round resident, pelagic 

Short-finned pilot 

whale 

Globicephala 

macrorhynchus 

* Small year-round population, peak 

late winter/early spring 

Sperm whale Physeter 

macrocephalus 

E Peak from November-April, 

generally pelagic 

Stejneger’s beaked 

whale 

Mesoplodon 

stejnegeri 

* Pelagic 

Striped dolphin Stenella 

coeruleoalba 

* Pelagic 
E-28

Table E-16. Marine Mammals Common in the NMFS Southwest Region (continued)

Common Name Scientific Name 

Federal 

Status 

under ESA 

Distribution 

Southern sea otter Enhydra lutris 

nereis

T Year-round resident 

Source: Geraci and Lounsbury 2005 

Notes: CH – Critical Habitat in the ROI 

E – Federally listed as endangered 

T – Federally listed as threatened 

* – only protected under MMPA 
E-29

Table E-17. Marine Mammals Common in the NMFS Northwest Region 

Common Name Scientific Name 

Federal 

Status 

under ESA 

Distribution 

Otariids (eared seals or sea lions) 

Northern elephant 

seal 

Mirounga 

angustirostris

* Year-round resident 

California sea lion Zalophus 

californianus

* Year-round resident 

Steller sea lion Eumetopias jubatus T/CH Visitor to area from southern 

breeding grounds, coastal to 

pelagic 

Northern fur seal Callorhinus 

ursinus

* Year-round resident 

Phocids (true or earless seals) 

Harbor seal Phoca vitulina * Year-round resident 

Mysticetes (baleen whales) 

Blue whale Balaenoptera 

musculus 

E Occur spring-fall; pelagic but may 

frequent coastal waters and shallow 

banks 

Gray whale Eschrichtius 

robustus

* Found March-May, OctoberDecember, few in summer 

Fin whale Balaenoptera 

physalus 

E Occur in summer, generally 

pelagic, visits coastal waters in 

many areas, migratory 

Humpback whale Megaptera 

novaeangliae

E Migratory population, with peak 

abundance mainly during summer 

but also in autumn 

Minke whale Balaenoptera 

acutorostrata

* Year-round resident; frequents 

coastal regions, bays, and offshore 

banks 

North Pacific right 

whale 

Eubalaena 

japonica 

E Uncommon 

Sei whale Balaenoptera 

borealis 

E Seen in summer and fall 

Odontocetes (toothed whales and dolphins) 

Baird’s beaked 

whale 

Berardius bairdii * Occur April-October, pelagic 

Cuvier’s beaked 

whale 

Ziphius cavirostris * Pelagic 

False killer whale Pseudorca 

crassidens 

* Occasional, pelagic 

Hubb’s beaked 

whale 

Mesoplodon 

carlhubbsi 

* Pelagic 
E-30

Table E-17. Marine Mammals Common in the NMFS Northwest Region (continued) 

Common Name Scientific Name 

Federal 

Status 

under ESA 

Distribution 

Killer whale Orcinus orca */E Southern Resident population listed 

as endangered. Inshore year-round. 

Stejneger’s beaked 

whale 

Mesoplodon 

stejnegeri 

* Pelagic 

Sperm whale Physeter 

macrocephalus 

E Seen spring-fall, generally pelagic 

Pacific white-sided 

dolphin 

Lagenorhynchus 

obliquidens

* Year-round resident, generally 

pelagic, nearshore in deep water 

Pygmy sperm 

whale 

Kogia breviceps * Pelagic 

Northern right 

whale dolphin 

Lissodelphis 

borealis 

* Uncommon 

Risso’s dolphin Grampus griseus * Occur spring-fall, pelagic 

Short-finned pilot 

whale 

Globicephala 

macrorhynchus 

* Uncommon 

Short-beaked 

common dolphin 

Delphinus delphis * Rare, pelagic 

Striped dolphin Stenella 

coeruleoalba 

* Rare, pelagic 

Dall’s porpoise Phocoenoides dalli * Year-round resident, pelagic; 

nearshore in deep water 

Harbor porpoise Phocoena 

phocoena 

* Coastal in bays, estuaries, and 

rivers; frequent offshore banks 

Source: Geraci and Lounsbury 2005 

Notes: CH – Critical Habitat in the ROI

E – Federally listed as endangered 

T – Federally listed as threatened 

* – only protected under MMPA 
E-31

Table E-18. Marine Mammals Common in the NMFS Alaska Region

Common Name Scientific Name 

Federal 

Status 

under ESA 

Distribution 

Otariids (eared seals or sea lions) 

Bearded seal Erignathus 

barbatus 

* Occur along continental shelf of 

Beaufort, Chukchi, and Bering Seas

Northern fur seal Callorhinus 

ursinus

* Found in Pribilof Islands and San 

Miguel Island, breeding areas, 

occur summer-fall 

Steller sea lion Eumetopias 

jubatus

T/E/CH Distributed around North Pacific 

rim, northward to Bering Sea and 

along eastern shore of Kamchatka 

Peninsula, Gulf of Alaska, and 

Aleutian Islands 

Phocids (true or earless seals) 

Harbor seal Phoca vitulina * Year-round resident, northern 

extent is Bristol Bay/Kuskokwim 

Bay area 

Northern elephant 

seal 

Mirounga 

angustirostris 

* Males feed near eastern Aleutian 

Islands, and in Gulf of Alaska 

Ribbon seal Histriophoca 

fasciata 

* Found in Bering and Chukchi seas; 

winter-spring, offshore along ice 

front; summer range unknown; 

breeds along ice front 

Ringed seal Phoca hispida * Found in southern Bering Sea 

Spotted seal Phoca largha * Occur along continental shelf of 

Beaufort, Chukchi, and Bering Seas

Odobenids (walrus) 

Walrus Odobenus 

rosmarus 

divergens 

* Found in shallow water areas, close 

to ice or land; geographic range 

mainly in Bering and Chukchi Seas 

ice pack. 

Mysticetes (baleen whales) 

Blue whale Balaenoptera 

musculus

E Occur from the Gulf of Alaska to 

the Aleutian Islands, pelagic, may 

frequent coastal waters and shallow 

banks 

Bowhead whale Balaena mysticetus E Occur in the coastal and offshore 

regions, mostly along ice fronts and 

leads, migratory 

Fin whale B. physalus E Common in summer, generally 

pelagic, visits coastal waters in 

many areas, migratory 

Gray whale Eschrichtius 

robustus

* Migrate along the Alaskan coast in 

winter and early spring; inhabit the 

eastern Alaskan waters during 

summer; occur in both the Bering 

and Chukchi seas 
E-32

Table E-18. Marine Mammals Common in the NMFS Alaska Region (continued)

Common Name Scientific Name 

Federal 

Status 

under ESA 

Distribution 

Humpback whale Megaptera 

novaeangliae

E Common in summer, coastal in 

many areas, migratory 

Minke whale B. acutorostrata * Common in summer, frequent 

coastal regions, bays, and offshore 

banks 

North Pacific right 

whale 

Eubalaena 

japonica 

E Occur in Gulf of Alaska and Bering 

Sea 

Sei whale Balaenoptera 

borealis 

E Occur in southern Alaska during 

summer and fall, pelagic 

Odontocetes (toothed whales and dolphins) 

Baird’s beaked 

whale 

Berardius bairdii * Occur in southern part of Alaska 

during winter, pelagic 

Beluga whale Delphinapterus 

leucas 

E (Cook 

Inlet Stock 

only) 

Coastal in bays, estuaries, and 

rivers; migratory along leads; 

winter offshore in pack ice 

Cuvier’s beaked 

whale 

Ziphius cavirostris * Occur in the Aleutian islands, 

pelagic 

Killer whale Orcinus orca * Common, inhabit coastal waters 

throughout SE Alaska, Gulf of 

Alaska, and Aleutian Islands 

Dall’s porpoise Phocoenoides dalii * Occur south of the Bering Strait, 

pelagic, nearshore in deep water, 

found frequently in inside waters of 

SE Alaska 

Harbor porpoise Phocoena 

phocoena 

* Occur year-round in SE Alaska; 

coastal in bays, estuaries, and 

rivers; frequent offshore banks 

Narwhal Monodon 

monoceros 

* Rare, usually associated with pack 

ice and deep water 

Pacific Whitesided dolphin Lagenorynchus 

obliquidens 

* Common in Aleutian Islands in 

summer, pelagic, nearshore in deep 

water 

Stejneger’s beaked 

whale 

Mesoplodon 

stejnegeri 

* Pelagic 

Sperm whale Physeter 

macrocephalus 

E Common in summer, mostly males, 

generally pelagic 

Mustelids (otters) 

Northern sea otter Enhydra lutris 

keyoni 

T 

(southwest 

DPS) 

Lives in shallow water areas along 

the shores of the North Pacific 

 

 
E-33

Table E-18. Marine Mammals Common in the NMFS Alaska Region (continued)

Common Name Scientific Name 

Federal 

Status 

under ESA 

Distribution 

Polar bear Ursus maritimus T Rear round resident of the Arctic 

Circle 

Source: Geraci and Lounsbury 2005, USFWS 2009 

Notes: CH – Critical Habitat in the ROI

E – Federally listed as endangered 

T – Federally listed as threatened 

* – only protected under MMPA
E-34

Table E-19. Marine Mammals Common in the NMFS Pacific Islands Region

Common Name Scientific Name 

Federal 

Status 

under ESA 

Distribution 

Phocids (true or earless seals)

Hawaiian Monk 

seal 

Monachus 

schauinslandi

E/CH Most common northwest of the 

main seven-island chain 

Mysticetes (baleen whales)

Blue whale Balaenoptera 

musculus 

E Population thought to occur in 

deeper offshore waters 

Bryde’s whale Balaenoptera 

edensi 

* Occurs throughout the main seven 

island chain January through April 

Fin whale Balaenoptera 

physalus 

E Occurs in winter 

Humpback whale Megaptera 

novaeangliae

E Occurs throughout the main seven 

island chain January through April 

Minke whale Balaenoptera 

acutorostrata 

* Occurs near Leeward Island 

North Pacific right 

whale 

Eubalaena 

japonica 

* Rare, most likely stray individuals 

from more northern populations 

Sei whale Balaenoptera 

borealis 

E In eastern North Pacific, 

population is migratory transient 

from coast of Mexico to Gulf of 

Alaska 

Odontocetes (toothed whales and dolphins) 

Blainville’s beaked 

whale 

Mesoplodon 

densirostris 

* Pelagic 

Bottlenose dolphin Tursiops truncatus * Common along the coastlines 

Cuvier’s beaked 

whale 

Ziphius cavirostris * Rare 

Dwarf sperm whale Kogia sima * Pelagic 

False killer whale Pseudorca 

crassidens 

* Occasionally seen between the 

main Hawaiian islands, pelagic 

Fin whale Balaenoptera 

physalus 

E Common in winter, visits coastal 

waters in many areas, migratory 

Fraser’s dolphin Lagenodelphis 

hosei 

* Pelagic 

Killer whale Orcinus orca * Rare 

Melon-headed 

whale 

Peponocephala 

electra 

* Occasionally seen between the 

main Hawaiian islands, pelagic 

Pantropical spotted 

dolphin 

Stenella attenuata * Common along the coastlines 

Pygmy killer whale Feresa attenuata * Occasionally seen between the 

main Hawaiian islands, pelagic 
E-35

Table E-19. Marine Mammals Common in the NMFS Pacific Islands Region 

(continued)

Common Name Scientific Name 

Federal 

Status 

under ESA 

Distribution 

Pygmy sperm whale Kogia breviceps * Pelagic 

Rough-toothed 

dolphin 

Steno bredanensis * Pelagic 

Short-finned pilot 

whale 

Globicephala 

macrorhynchus 

* Occasionally between the main 

Hawaiian islands, pelagic 

Sperm whale Physeter 

macrocephalus 

E In deeper waters off Hawaii, yearround resident 

Striped dolphin Stenella 

coeruleoalba 

* Pelagic 

Spinner dolphin Stenella 

longirostris

* Pelagic and coastal, daytime in 

shallow bays 

Source: Geraci and Lounsbury 2005 

Notes: CH – Critical Habitat in the ROI 

E – Federally listed as endangered 

* – only protected under MMPA

APPENDIX F 

NATIONAL MARINE MAMMAL STRANDING NETWORK AND 

DISENTANGLEMENT NETWORK MEMBERS

F-1

Marine Mammal Stranding Network 

Organization/Individual Location Authority Rehabilitation 

(NMFS Species) 

NMFS Northeast Region

Allied Whale, College of the 

Atlantic Bar Harbor, ME SA N/A 

Maine Department of Marine 

Resources Boothbay Harbor, ME 109(h) N/A 

University of New England Biddeford, ME SA Pinnipeds, Small 

Cetaceans 

The Whale Center of New England Gloucester, MA Designee of 

NEAQ N/A 

New England Aquarium (NEAQ) Boston, MA SA Pinnipeds, Small 

Cetaceans 

The National Marine Life Center, 

Inc. Buzzards Bay, MA Designee of NEAQ Pinnipeds 

International Fund for Animal 

Welfare (IFAW)- Cape Cod 

Stranding Network 

Buzzards Bay, MA SA N/A 

Cape Cod National Seashore Wellfleet, MA 109(h) N/A 

Mystic Aquarium Mystic, CT SA Pinnipeds, Small 

Cetaceans 

Riverhead Foundation for Marine 

Research Riverhead, NY SA Pinnipeds, Small Cetaceans 

Marine Mammal Stranding Center Brigantine, NJ SA Pinnipeds 

MERR Institute, Inc. Nassau, DE 

Designee of 

Delaware 

DNREC 

N/A 

Maryland Department of Natural 

Resources, Cooperative Oxford 

Laboratory 

Oxford, MD 109(h) N/A 

National Aquarium in Baltimore Baltimore, MD SA Pinnipeds, Small 

Cetaceans 

Smithsonian Institute, National 

Museum of Natural History Washington, D.C. SA N/A 

Virginia Aquarium and Marine 

Science Center Virginia Beach, VA SA Pinnipeds 

Virginia Institute of Marine Science, 

College of William and Mary Gloucester Point, VA SA N/A 

NMFS Southeast Region

Duke University Marine Laboratory Beaufort, NC Designee of 

UNCW N/A 

NMFS, SEFSC Beaufort Laboratory Beaufort, NC 109(h) N/A 

NC State College of Veterinary 

Medicine, Center for Marine 

Science and Technologies 

Morehead City, NC Designee of 

UNCW N/A 

University of North Carolina at 

Wilmington (UNCW), Biological 

Sciences 

Wilmington, NC SA N/A 

 
F-2

Organization/Individual Location Authority Rehabilitation 

(NMFS Species) 

NMFS Southeast Region (continued)

North Carolina Aquarium at Fort 

Fisher Fort Fisher, NC 109(h) N/A 

Coastal Carolina University Conway, SC SA N/A 

National Ocean Service (NOS) 

Charleston Laboratory Charleston, SC 109(h) N/A 

South Carolina Wildlife and Marine 

Resources Division Charleston, SC 109(h) N/A 

Georgia Department of Natural 

Resources, Non-Game Endangered 

Wildlife Program 

Brunswick, GA 109(h)and SA N/A 

Clearwater Marine Aquarium Clearwater, FL SA Small Cetaceans 

Dynamac Corporation Kennedy Space Center, FL SA N/A 

FWC Apalachicola National 

Reserve Eastpoint, FL 109(h) N/A 

Gulf Islands National Seashore Gulf Breeze, FL 109(h) N/A 

Gulf World Marine Park Panama City Beach, FL SA Small Cetaceans 

Harbor Branch Oceanographic 

Institute, Inc. Fort Pierce, FL SA N/A 

Hubbs-SeaWorld Research Institute Orlando, FL SA N/A 

Marine Animal Rescue Society Miami, FL SA Small Cetaceans 

Marine Mammal Conservancy, Inc. Key Largo, FL SA Small Cetaceans 

Marine Mammal Stranding 

Network-Southwest Region Cape Coral, FL SA N/A 

Mote Marine Laboratory Sarasota, FL SA Small Cetaceans 

NMFS, SEFSC Miami Laboratory Miami, FL 109(h) N/A 

NMFS, SEFSC Panama City 

Laboratory Panama City, FL 109(h) N/A 

SeaWorld Orlando Orlando, FL SA Pinnipeds 

The Florida Aquarium Tampa, FL SA N/A 

Emerald Coast Wildlife Refuge, Inc Destin, FL SA N/A 

Northwest Florida Aquatic 

Preserves Office, FDEP Milton, FL 109(h) N/A 

Marterra Foundation, Inc. Mobile, AL SA N/A 

Gulf Islands National Seashore Ocean Springs, MS 109(h) N/A 

Institute for Marine Mammal 

Studies Gulfport, MS SA Small Cetaceans 

Mississippi Department of Marine 

Resources Biloxi, MS 109(h) N/A 

NMFS, SEFSC Pascagoula 

Laboratory Pascagoula, MS 109(h) N/A 

Louisiana Marine Mammal 

Stranding Network- Audubon 

Aquarium of the Americas 

New Orleans, LA SA Small Cetaceans 

Louisiana Department of Wildlife 

and Fisheries Lake Charles, LA 109(h) N/A 

Aransas National Wildlife Refuge Austwell, TX 109(h) N/A 

NMFS, SEFSC Galveston 

Laboratory Galveston, TX 109(h) N/A 

Texas Marine Mammal Stranding 

Network (TMMSN) 

Galveston, TX 

Corpus Christi, TX SA Small Cetaceans 
F-3

Organization/Individual Location Authority Rehabilitation 

(NMFS Species) 

NMFS Southeast Region (continued)

Texas State Aquarium Corpus Christi, TX Designee of 

TMMSN Small Cetaceans 

Texas Parks and Wildlife Austin, TX 109(h) N/A 

Virgin Islands Division of Fish and 

Wildlife Frederiksted, VI 109(h) N/A 

Puerto Rico Department of Natural 

and Environmental Resources 

(PRDNER) 

Santurce, PR 109(h)/SA N/A 

Mayaguez Zoo Mayaguez, PR Designee of 

PRDNER Pinnipeds 

NMFS Southwest Region

Northcoast Marine Mammal Center Crescent City, CA SA Pinnipeds, Small 

Cetaceans 

The Marine Mammal Center Sausalito, CA SA Pinnipeds, Small 

Cetaceans 

Long Marine Laboratory, University 

of California at Santa Cruz Santa Cruz, CA SA Small Cetaceans 

Long Beach Animal Control Long Beach, CA 109(h) N/A 

Santa Barbara Marine Mammal 

Center Santa Barbara, CA SA Pinnipeds, Small 

Cetaceans 

Santa Barbara Museum of Natural 

History Santa Barbara, CA SA N/A 

Fort MacArthur Marine Mammal 

Care Center San Pedro, CA SA Pinnipeds, Small Cetaceans 

Pacific Marine Mammal Center Laguna Beach, CA SA Pinnipeds, Small 

Cetaceans 

SeaWorld San Diego San Diego, CA SA Pinnipeds, Small 

Cetaceans 

Los Angeles County Museum of 

Natural History Los Angeles, CA SA N/A 

Moss Landing Marine Laboratories Moss Landing, CA SA N/A 

NMFS Southwest Fisheries Science 

Center La Jolla, CA 109(h) N/A 

California Academy of Sciences, 

Department of Ornithology & 

Mammalogy 

San Francisco, CA SA N/A 

Humboldt State University, 

Vertebrate Museum Arcata, CA SA N/A 

California Wildlife Center Malibu, CA 109(h) N/A 

Marine Animal Rescue Topanga, CA 109(h) N/A 

Channel Islands Marine and 

Wildlife Institute Goleta, CA SA Pinnipeds, Small 

Cetaceans 

Los Angeles County Lifeguards Los Angeles County, CA 109(h) N/A 

Wildrescue Malibu, CA 109(h) N/A 

NMFS Northwest Region 

Cascadia Research Collective Olympia, WA Contingency 

Plan N/A 

Central Puget Sound Marine 

Mammal Stranding Network Whidbey Island, WA SA N/A 

Dungeness National Wildlife 

Refuge Port Angeles, WA 109(h) N/A 
F-4

Organization/Individual Location Authority Rehabilitation 

(NMFS Species) 

NMFS Northwest Region (continued)

Edmonds Animal Control Edmonds, WA 109(h) N/A 

Makah Tribe Neah Bay, WA 

Contingency 

Plan/Designee 

(NMFS, 

NWR) 

N/A 

NMFS, Northwest Regional Office Seattle, WA 109(h) N/A 

NMFS, Northwest Fisheries 

Science Center Seattle, WA 109(h) N/A 

NMFS, National Marine Mammal 

Laboratory Seattle, WA 109(h) N/A 

Olympic Coast National Marine 

Sanctuary Port Angeles, WA 109(h) N/A 

Olympic Coast National Park Port Angeles, WA 109(h) N/A 

Point Defiance Zoo and Aquarium Tacoma, WA Contingency 

Plan Inactive 

East Jefferson County Marine 

Mammal Stranding Network Port Townsend, WA SA N/A 

Progressive Animal Welfare Society Lynwood, WA Contingency 

Plan Pinnipeds 

Killer Whale Tales Seattle, WA 

Designee 

(NMFS, 

NWR) 

N/A 

Seattle Animal Control Seattle, WA 109(h) N/A 

Seattle Parks and Recreation Seattle, WA 109(h) N/A 

San Juan County Marine Mammal 

Stranding Network Friday Harbor, WA Contingency 

Plan N/A 

The Whale Museum Friday Harbor, WA SA N/A 

Washington Department of Fish and 

Wildlife Olympia, WA 109(h) N/A 

Whatcom County Marine Mammal 

Stranding Network Bellingham, WA 

Designee 

(NMFS, 

NWR) 

N/A 

Wolf Hollow Wildlife 

Rehabilitation Center Friday Harbor, WA Contingency Plan Pinnipeds 

Wolftown Rehabilitation Vashon Island, WA 

Designee 

(NMFS, 

NWR) 

N/A 

Free Flight Wildlife Rehabilitation 

Center Bandon, OR 

Designee 

(NMFS, 

NWR) 

Pinnipeds 

Oregon State Police Statewide 109(h) N/A 

Oregon Coast Aquarium Newport, OR 

Designee 

(NMFS, 

NWR) 

Inactive 

Oregon Department of Fish and 

Wildlife Salem, OR 109(h) N/A 

Oregon Institute of Marine Biology Charleston, OR SA N/A 

Oregon State University Newport, OR SA N/A 

Portland State University Portland, OR SA N/A 

 
F-5

Organization/Individual Location Authority Rehabilitation 

(NMFS Species) 

NMFS Alaska Region

Alaska SeaLife Center Seward, AK SA Pinnipeds, Small 

Cetaceans 

Aleut Community of St. Paul Island 

Tribal Government St. Paul Island, AK SA N/A 

Alaska Sea Otter and Stellar Sea 

Lion Commission Anchorage, AK SA N/A 

Alaska Whale Foundation Petersburg, AK SA N/A 

University of Alaska FairbanksMuseum of the North Fairbanks, AK SA N/A 

Andy Aderman, Togiak National 

Wildlife Refuge Dillingham, AK 109(h) N/A 

Kimberly Beckman, 

Alaska Department of Fish and 

Game 

Fairbanks, AK 109(h) N/A 

Jamie King, Alaska Department of 

Fish and Game Haines, AK 109(h) N/A 

Reid Brewer, University of Alaska, 

Fairbanks/Sea Grant Dutch Harbor, AK 

Affiliate with 

Kate Wynne’s 

SA 

N/A 

Dr. Kathy Burek Eagle River, AK Affiliate 

w/ASLC’s SA N/A 

Gary Frietag, Southern Southeast 

Regional Aquaculture Association Ketchikan, AK SA N/A 

Chris Gabriele, National Park 

Service, Glacier Bay National Park Glacier Bay, AK 109(h)/SA N/A 

Eileen Henniger, Yakutat Tribe Yakutat, AK 109(h) N/A 

Lauri Jemison, 

Alaska Department of Fish and 

Game 

Juneau, AK 109(h) N/A 

North Gulf Oceanic Society Homer, AK SA N/A 

Lori Quakenbush, 

Alaska Department of Fish and 

Game 

Fairbanks, AK 109(h) N/A 

Gay Sheffield, 

Alaska Department of Fish and 

Game 

Nome, AK 109(h) N/A 

Jan Straley, University of Alaska 

Southeast, Sitka Campus Sitka, AK SA N/A 

Dr. Rachel Dziuba, Bridge 

Veterinary Services Juneau, AK SA N/A 

Jamie Womble, National Park 

Service, Glacier Bay National Park 

Juneau, AK 

Glacier Bay, AK 109(h) N/A 

Kate Wynne, University of Alaska, 

Fairbanks/Sea Grant Kodiak, AK SA N/A 

NMFS Pacific Islands Region

American Samoa Department of 

Marine and Wildlife Resources Pago Pago, AS SA/109(h) N/A 

Guam Department of Agriculture Hagatana, GU SA/109(h) N/A 

Hawaii Pacific University (HPU) Honolulu, HI SA N/A 

 
F-6

Organization/Individual Location Authority Rehabilitation 

(NMFS Species) 

NMFS Pacific Islands Region (continued)

Hawaiian Islands Humpback Whale 

National Marine Sanctuary Kihei, HI 109(h) N/A

Maui Marine Mammal Response 

Program Kihei, HI TBD N/A

Hawaii State Division of Aquatic 

Resources Honolulu, HI 109(h) N/A

Northern Mariana College Saipan, MP SA/109(h) N/A

University of Hawaii, Hilo Hilo, HI Designee of 

HPU N/A

NMFS Pacific Islands Fisheries 

Science Center Honolulu, HI 109(h) Pinnipeds 
F-7

Marine Mammal Disentanglement Network 

Individual Organization Location Responder 

Level 

NMFS Northeast Region

Charles Mayo Provincetown Center for Coastal 

Studies (PCCS) Provincetown, MA 5 

Scott Landry PCCS Provincetown, MA 5 

David Morin NMFS, Northeast Regional Office, 

Protected Resources Division Gloucester, MA 5 

Chris Slay New England Aquarium (NEAQ) Boston, MA 5 

Jamison Smith NMFS, Northeast Regional Office, 

Protected Resources Division Gloucester, MA 4 

Mackie Greene Campobello Whale Rescue Team 

Campobello Island, 

New Brunswick, 

Canada 

4 

Brian Sharp PCCS Provincetown, MA 4 

Sean Todd Allied Whale, College of the 

Atlantic Bar Harbor, ME 3 

Michael Neelon N/A ME 3 

Tom Fernald N/A ME 3 

Jooke Robbins PCCS Provincetown, MA 3 

Moira Brown NEAQ Boston, MA 3 

Lisa Conger NEAQ Boston, MA 3 

Amy Knowlton NEAQ Boston, MA 3 

Monica Zani NEAQ Boston, MA 3 

Scott Kraus NEAQ Boston, MA 3 

Phil Hamilton NEAQ Boston, MA 3 

Steve Brown International Fund for Animal 

Welfare (IFAW) 

Onboard IFAW’s 

Song of the Whale 3 

Timothy Cole NMFS, Northeast Fisheries 

Science Center Woods Hole, MA 3 

Fred Wenzel NMFS, Northeast Fisheries 

Science Center Woods Hole, MA 3 

Lisa Sette PCCS Provincetown, MA 3 

Glenn Salvador NMFS, Northeast Regional Office Belle Haven, VA 3 

Mark Swingle Virginia Aquarium and Marine 

Science Center 

Virginia Beach, 

VA 3 

Susan Barco Virginia Aquarium and Marine 

Science Center 

Virginia Beach, 

VA 3 

Jeff Thompson Virginia Aquarium and Marine 

Science Center 

Virginia Beach, 

VA 3 

NMFS Southeast Region

Clay George Georgia Department of Natural 

Resources (GADNR) Brunswick, GA 4 

Mark Dodd GADNR Brunswick, GA 4 

William McLellan 

Biological Sciences and Center for 

Marine Science, University of 

North Carolina, Wilmington 

Wilmington, NC 3 

Andrew Read Duke University Marine 

Laboratory Beaufort, NC 3 

Andrew Westgate Duke University Marine 

Laboratory Beaufort, NC 3 
F-8

Individual Organization Location Responder 

Level 

NMFS Southeast Region (continued)

Keith Rittmaster North Carolina Maritime Museum Beaufort, NC 3 

Adam MacKinnon GADNR Brunswick, GA 3 

Brad Winn GADNR Brunswick, GA 3 

Kate Sparks GADNR Brunswick, GA 3 

Tom Pitchford Florida Fish and Wildlife 

Conservation Commission (FWC) Jacksonville, FL 3 

Andy Garrett FWC Jacksonville, FL 3 

Barb Zoodsma NMFS, Southeast Regional Office, 

Protected Resources Division 

Fernandina Beach, 

FL 3 

Anthony Martinez NMFS, Southeast Fisheries 

Science Center Miami, FL 3 

Alicia Windham-Reid U.S. Geological Survey Gainesville, FL 3 

Bill Foster N/A NC 3 

John Pieno N/A NC 3 

Lou Browning N/A NC 3 

NMFS Alaska Region

Kate Wynne University of Alaska Fairbanks 

/Sea Grant Kodiak, AK 4 

Chris Gabriele Glacier Bay National Park Tenakee Springs, 

AK 4 

Jan Straley University of Alaska Southeast Sitka, AK 4 

Fred Sharpe Alaska Whale Foundation Petersburg, AK 4 

Pieter Folkens Alaska Whale Foundation Petersburg, AK 3 

Sean Hanser Alaska Whale Foundation Petersburg, AK 3 

Sara Graef Alaska Whale Foundation Petersburg, AK 3 

Bree Witteveen University of Alaska Fairbanks 

/Sea Grant Kodiak, AK 3 

Steve Lewis N/A Tenakee Springs, 

AK 3 

Dan Vos N/A Anchorage, AK 3 

Bob Foy University of Alaska Fairbanks Kodiak, AK 3 

Mark Witteveen Alaska Department of Fish and 

Game Kodiak, AK 3 

 Jim Wisher NMFS Office of Law Enforcement Homer, AK 3 

Tim Lebling Alaska Sea Life Center Seward, AK 3 

Janet Neilson Glacier Bay National Park 3 

Don Holmes Petersburg Marine Mammal Center Petersburg, AK 3 

Barry Bracken Petersburg Marine Mammal Center Petersburg, AK 3 

Dennis Thaute NMFS Office of Law Enforcement Homer, AK 3 

Aleria Jensen NMFS Alaska Regional Office, 

Protected Resources Division Juneau, AK 3 

Kaja Brix NMFS Alaska Regional Office, 

Protected Resources Division Juneau, AK 3 

NMFS Pacific Islands Region

Edward Lyman 

NOS, Hawaiian Islands Humpback 

Whale National Marine Sanctuary 

(HIHWNMS) 

Kihei, Maui, HI 5 

David Mattila NOS, HIHWNMS Kihei, Maui, HI 5 

Joe Arcenaux NOAA, Pacific Islands Regional 

Office Oahu, HI 3 
F-9

Individual Organization Location Responder 

Level 

NMFS Pacific Islands Region (continued)

Bart Bottoms Veterinarian HI 3 

Brent Carman Hawaii Department of Land and 

Natural Resources (DLNR) Hawaii, HI 3 

Marie Chapla-Hill NOAA, Pacific Islands Fisheries 

Science Center Oahu, HI 3 

Mark Deakos Hawaii Marine Mammal Research Maui, HI 3 

Skippy Hau Hawaii DLNR Maui, HI 3 

Alistair Hebard NOS, HIHWNMS Kihei, Maui, HI 3 

Ben LaCour NOS, HIHWNMS Kihei, Maui, HI 3 

Greg Levine N/A Oahu, HI 3 

Allan Ligon NOS, HIHWNMS Maui, HI 3 

Charles Littnan NOAA, Pacific Islands Fisheries 

Science Center Oahu, HI 3 

John Mitchell Hawaii DLNR Oahu, HI 3 

David Nichols Hawaii DLNR Oahu, HI 3 

Adam Pack University of Hawaii, Hilo Hawaii, HI 3 

Rod Quigley MOC HI 3 

Susan Richards Hawaiian Marine Mammal 

Consortium Hawaii, HI 3 

David Schofield NMFS, Pacific Islands Regional 

Office Oahu, HI 3 

Russell Sparks Hawaii DLNR Maui, HI 3 

Kosta Stamoulis Hawaii DLNR Maui, HI 3 

Grant Thompson KIRC HI 3 

Jason Turner University of Hawaii, Hilo Hawaii, HI 3 

Vaughan Tyndzik Hawaii DLNR Kauai, HI 3 

Justin Viezebicke NOS, HIHWNMS Hawaii, HI 3 

Jeff Walters Hawaii DLNR Oahu, HI 3 

Paul Wong NOS, HIHWNMS Oahu, HI 3 

Suzanne Yin Hawaiian Marine Mammal 

Consortium Hawaii, HI 3 

Chad Yoshinago NOAA, Pacific Islands Fisheries 

Science Center Oahu, HI 3 

NMFS Southwest Region

*The NMFS Southwest Region Disentanglement Network is currently in development, and Responder Levels 

have not been designated. Below are the current Disentanglement Team Leads. 

David Casper

Long Marine Laboratory, 

University of California, Santa 

Cruz

Santa Cruz, CA N/A 

Pieter Folkens Alaska Whale Foundation Benecia, CA N/A 

Dean Gomersall Pacific Marine Mammal Center Laguna Beach, CA N/A 

Jim Harvey Moss Landing Marine Laboratories Moss Landing, CA N/A 

Peter Howorth SBMMC Santa Barbara Marine 

Mammal Center Santa Barbara, CA N/A 

Peter Wallerstein Marine Animal Rescue Topanga, CA N/A 

Keith Yip SeaWorld San Diego San Diego, CA N/A 

NMFS Northwest Region

*The NMFS Northwest Region Disentanglement Network is currently in development, and Responder Levels 

have not been designated. 
THIS PAGE INTENTIONALLY LEFT BLANK 
Photo by Lynne Barre, 

Photo by PCCS 

Photo by NMFS NWR 

Final Programmatic Environmental Impact Statement 

for the Marine Mammal Health and 

Stranding Response Program 

February 2009 

Volume III: Appendices G-N 

Photo by ASLC 

Photo by Ingrid Overgard 

National Marine Fisheries Service 

Office of Protected Resources 

1315 East-West Highway 

Silver Spring, MD 20910 

APPENDIX G 

NMFS PERMIT NO. 932-1489-10 

UNITED STATES DEPARTMENT OF COMMERCE 

National Oceanic and Atmospheric Administration 

NATIONAL MARINE FISHERIES SERVICE 

S~lver Spr~ng. MD 2091 0 

JUN 2 0 2008 

Teri Rowles, D.V.M., Ph.D. 

National Coordinator, MMHSRP 

Office of Protected Resources 

National Marine Fisheries Service 

13 15 East-West Highway 

Silver Spring, Maryland 209 10 

Dear Dr. Rowles: 

Enclosed is an amendment to Permit No. 932-1489-09, for enhancement and research activities 

on marine mammals. The amendment has been assigned Permit No. 932-1489-10 and the 

changes to specific Terms and Conditions are reflected in bold font in the attached permit. This 

permit amendment is effective upon your signature and valid through June 30,2009 or until the 

new permit (application File No. 932-1905) is issued, whichever comes first. Please note that 

this permit amendment replaces all previous versions of the permit. 

Both an original and a "file copy" of the signature page are enclosed with your amended permit. 

Please sign and date both signature pages where indicated, keeping the original with the permit 

for your records. You must return the ''file copy" signature page, with your dated signature, to 

this office as proof of your acceptance of the permit. Please return the signature page marked 

"file copy" to the Chief, Permits Division (FIPRl), 13 15 East-West Highway, Silver Spring, WID 

20910. You may also submit the "file copy" of the signature page by facsimile to 301-427-2521 

and confirm it by mail. 

As the Responsible Party of this amended permit, you are ultimately responsible for all activities 

of any individual operating under its authority. Therefore, you should read all sections of the 

amended permit carefully before signing it and before conducting any activities pursuant to the 

amended permit. If you have any problems or questions, please contact Amy Sloan or Carrie 

Hubard at 30 1-7 13-2289 before signing the amended permit. 

,-- '-7 Sincerely, ') 

Chief, Permits, consew 

and Education Division 

Office of Protected Resources 

Enclosure 

@ Printed on Recycled Paper 
UNITED STATES OEPARTMENT OF COMMERCE 

National Oceanic and Atmospheric Administration 

NATIONAL MARINE FISHERIES SERVICE 

Silver Spring, MD 209 1 0 

NMFS Permit No. 932-1489-10 

Expiration Date: June 30,2009 

SCIENTIFIC RESEARCH and ENHANCEMENT PERMIT 

TO TAKE MARINE MAMMALS 

Authorization 

The Marine Mammal Health and Stranding Response Program (MMHSRP), Office of Protected 

Resources, National Marine Fisheries Service (NMFS) [Responsible Party and Principal 

Investigator (PI): Dr. Teri Rowles], is hereby authorized to take marine mammals in the manner 

specified below for the purpose of scientific research and enhancement, subject to the provisions of 

the Marine Mammal Protection Act of 1972 (MMPA; 16 U.S.C. 136 1 et seq.), the Regulations 

Governing the Taking and lmporting of Marine Mammals (50 CFR part 216), the Endangered 

Species Act of 1973, as amended (ESA; 16 U.S.C. 1531 et seq.), the Regulations Governing the 

Taking, Importing, and Exporting of Endangered and Threatened Fish and Wildlife (50 CFR parts 

222-226), the Fur Seal Act of 1966, as amended (FSA; 16 U.S.C. 1151 et seq.), and the Terms and 

Conditions hereinafter set out. This permit, as amended, supersedes all previous versions. 

Abstract 

The purposes of the authorized activities, as stated in the application, are to: (1) collect, receive, 

preserve, label, and transport marine mammal cadavers, hard parts, tissue, and fluid samples for 

physical, chemical, or biological analyses, import, and export; (2) take stranded or distressed 

marine mammals and endangered or threatened species; (3) salvage specimens from dead marine 

mammals and endangered or threatened species; (4) conduct aerial surveys to locate imperiled 

marine mammals or survey the extent of disease outbreaks or die-offs; (5) harass marine mammals 

on land incidental to other MMHSW activities authorized by this permit; and (6) develop and 

maintain cell lines from species under NMFS jurisdiction. 

A. Number and Kind(s) of Marine Mammals and Location(s) [50 CFR 217.36(a)(i)] 

1. PROJECT I - SPECIMEN COILLECTION: MARINE MAMMAL AND 

ENDANGERED OR THREATENED SPECIES 

a. At any time of the year, the Pennit Holder, PI, and Co-investigators (CIS) 

[hereinafter "Researchers"] may, subject to the conditions herein, collect, 

receive, analyze, archive, and importlexport (worldwide), unlimited 

numbers and kinds of specimens, including cell lines, from the following 

marine mammal and endangered or threatened species: 

1) Order Cetacea; and 

2) Order Pinnipedia (except walrus). 

@ Printed on Recycled Pape~ 
b. The specimens authorized in A.1.a. may be taken from any of the following 

sources: 

1) On-going live animal capturelrelease programs as authorized under 

Part A.2. 

2) Live animal capturehelease as part of a disease, emergency response 

or die-off investigation; 

3) Live animals stranded or in rehabilitation (specimens may include 

biopsies); 

4) Captive animals when sampling is beyond the scope of normal 

husbandry; 

5) Directly taken in fisheries for such animals where such taking is 

legal and humane; 

6) Killed during subsistence harvests by native communities; 

7) Killed incidental to commercial fishing operations; 

8) Killed incidental to other human activities (e.g., ship strikes, 

blasting, etc.); 

9) Found dead on the beach or at sea; 

10) Found dead as part of NOAA investigations (e.g., hazmat spills, oil 

spills, harmful algal blooms, etc.); 

11) Found on the beach or on land within 114 mile of the ocean (bones, 

teeth or ivory of any dead animal); 

12) Soft parts sloughed, excreted, or discharged; or 

13) Specimens from other permitted research and authorized activities. 

c. Researchers may receive/possess samples taken from species of the Order 

Sirenia, polar bear (Ursus maritimus), sea otter (Enhydra lutris), and marine 

otter (Lontra felina). 

NMFS Permit No. 932-1489-10 

Expiration Date: June 30, 2009 
2. PROJECT I1 - ENHANCEMENT ACTIVITIES : MARINE MAMMALS AND 

ENDANGERED OR THREATENED SPECIES 

a. Researchers may "take", as defined in the MMPA and ESA', live marine 

mammals that are stranded; entangled; disentangled; trapped out of habitat; in 

peril (e.g., in vicinity of an oil spill); injured; part of a population that is 

experiencing or has experienced a die-off, unusual mortality event, or repeat 

morbiditylmortality event; extra-limital; and nuisance marine mammals and 

endangered or threatened species by the following activities: 

1) Capturelrelease or if capture is not necessary, use means available (as 

approved by the Permit HolderIPI or a CI) to lure trapped or nuisance 

animals out to sea or deter them away from an area of imminent danger; 

2) Treat distressed conditions, including temporary captivity in an adequate 

treatment or rehabilitation facility; 

3) Disentangle from gear, ropes or other material which may be adversely 

affecting the animal; 

4) Transport for rehabilitation or return to wild; 

5) Attach tags to andlor biopsy; conduct auditory brainstem response and 

auditory evoked potential procedures; or 

6) Euthanize animals for humane or medical reasons (see B.2.b.). 

b. Researchers may harass marine mammals during aerial surveys to locate 

imperiled marine mammals or to survey the extent of a disease outbreak or dieoff. 

c. Researchers may harass m'arine mammals on land incidental to MNIHSRP 

activities authorized by this permit. 

'AS defined in the MMPA and promulgating regulations, "take" means to harass, hunt, collect, capture, or 

kill, or to attempt to harass, hunt, collect caphue, or kill any marine mammal; as defined in the ESA, "take" means to 

harass, harm, pursue, hunt, shoot, wound, kill, trap, or collect, or attempt to engage in such conduct. 

3 

NMFS Permit No. 932-1489-10 

Expiration Date: June 30, 2009 
3. PROJECT 111 - IMPORTIEXPORT OF LIVE MARINE NIAMMALS [MMPA 

5 109(h)1 

a. At any time of the year, Researchers may importlexport (worldwide), nonlisted marine mammals, for medical treatment, from the following species: 

1) Order Cetacea (except endangered or threatened species); and 

2) Order Pinnipedia (except walrus and endangered species). 

B. ResearchIEnhancement Conditions [50 CFR 2 16.36(b)] 

1. PROJECT I - SPECIMEN COLLECTION: MARINE MAMMALS AND 

ENDANGERED OR THREATENED SPECIES 

a. The Working Group on Unusual Marine Mammal Mortality Events 

(WGUMMME) will provide advice on any live animal investigative 

activities. 

b. Only experienced and trained personnel will perform any live animal 

investigative activities. 

c. Samples in A. 1 .c. may be acquired and possessed only if the samples were 

taken under authority of a U.S. Fish and Wildlife Service permit or 

authorization and samples were taken in a humane manner. 

2. PROJECT I1 - ENHANCEMENT ACTIVITIES: MARINE MAMMALS AND 

ENDANGERED OR THREATENED SPECIES 

1) Prior to release, Researchers may tag marine mammals and 

threatened or endangered species undergoing rehabilitation; 

2) Animals entangled in rope or other debris may be tagged and 

monitored; and 

3) Only experienced personnel can apply and deploy tags by acceptable 

means. 

NMFS Permit No. 932-1489-10 

Expiration Date: June 30,2009 
b. Euthanasia 

1) For ESA-listed species, the NMFS National Stranding 

Coordinator(s) must be consulted and provide approval (verbal or 

written), in advance, of euthanasia for humane or medical purposes; 

and 

2) For both MMPA and ESA-listed species, euthanasia must only be 

performed by an attending, experienced, and licensed veterinarian or 

other qualified individual according to applicable laws governing 

state veterinary practices. 

3. PROJECT I11 - IMPORTIEXPORT OF LIVE MARINE MAMMALS (MMPA 

§ 109(h)) 

a. Researchers may only import or export non-listed marine mammals for 

medical treatment, rehabilitation or return to wild (including the return of 

extra-limital animals). 

b. The Convention on International Trade in Endangered Species (CITES) 

shall apply to imports and exports authorized in this Project. 

4. PROJECTS I, I1 and I11 

a. The following individuals may participate in the conduct of the activities 

authorized herein: Teri Rowles, Ph.D., D.V.M. (Responsible PartyPI) and 

Janet Whaley, D.V.M. (CI). Dr. Rowles or Dr. Whaley may designate 

additional individuals to participate as CIS in the conduct of the research and 

enhancement activities authorized herein. Each additional CI must receive a 

letter from Dr. Rowles or Dr. Whaley confirming hislher status and detailing 

specific roles and responsibilities, attached to a copy of this permit. 

Designation of CIS is at the sole discretion of the Permit HolderIPI and may 

be rescinded at any time. 

b. The Permit HolderIPI, or an identified CI with approval of the Permit 

HolderIPI, may designate members of the National Stranding or 

Disentanglement Network that hold Stranding Agreements, other network 

participants, and/or other federal, state or local agencies or their employees, 

and other qualified individuals as agents of the Permit HolderIPI authorized 

under this permit to conduct activities authorized herein. 

c. Researchers may conduct activities by the means and for the purposes 

described in the application, as limited by the Terms and Conditions of this 

NMFS Permit No. 932-1489-10 

Expiration Date: June 30,2009 
permit, and as otherwise authorized by the Permit HolderIPI or identified 

CIS. 

d. For marine mammal and endangered species stranding response activities 

(including capturelrelease activities), the Permit HolderIPI andlor CIS must: 

1) Notify the Permits, Conservation and Education Division, Office of 

Protected Resources (hereinafter "Permits Division"), prior to any 

capturelrelease activities; 

2) Only perform capturelrelease activities as advised by the 

WGUMMME for any live animal investigative activities (B.1 .a.); 

3) Only perform capturelrelease activities in conjunction with 

researchers and managers for that stock or species; 

4) Process animals in small groups; 

5) Minimize handling time; 

6) Exercise caution when approaching all animals, particularly 

femalelpup or femalelcalf pairs; 

7) Monitor all biopsy or tagging sites for possible infection; 

8) Keep animals cool and wet during triage andlor transport (when 

appropriate); 

9) Use standardized, humane methods for sterilization and sample 

collection; and 

10) Use scientifically reviewed and acceptable tagging and biopsy 

sampling techniques that are not considered controversial. In no 

instance will Researchers attempt to biopsy a cetacean anywhere on 

the front half of the animal. 

e. For large whale disentanglements, Researchers must: 

1) Approach the whales gradually to minimize or avoid any sort of 

startle response; 

2) Use caution when approaching mothers and calves; and 

NMFS Permit No. 932-1489-10 

Expiration Date: June 30, 2009 
3) For the safety of the Researchers and whales, only use individuals 

that have been sufficiently trained, to the satisfaction of the Permit 

HolderBI, to disentangle animals. 

f. Researchers must perform all activities and collect all samples in a humane 

manner. 

g. Researchers must not kill any animal for the express purpose of providing 

specimens to be obtained and/or imported/exported under this permit. 

h. Researchers must assign a permanent catalogue number, including any prior 

identification numbers, to all individuals or samples. 

5. IMPORTIEXPORT REQUIREMENTS 

a. Researchers must not import specimens into the United States from marine 

mammals: 

1) Taken illegally in the country of origin or taken in a directed fishery, 

unless such taking is legal and humane; 

2) Taken in any high seas driftnet fishery after December 3 1, 1992; 

3) . Taken during any commercial whaling operation or any scientific 

whaling operation which does not meet the criteria established by the 

International Whaling Commission at the time of taking; or 

4) Deliberately kilned for the purposes of fulfilling this permit. 

b. Researchers must comply with the requirements of the CITES for import 

and export [50 CFR part 231. 

c. Marine mammals and marine mammal parts imported under the authority of 

this permit must be taken, imported or exported in a humane manner, and in 

compliance with the Acts and any applicable foreign law. Importation of 

marine mammals and marine mammal parts is subject to the provisions of 

50 CFR parts 14 and 216. 

d. All specimens imported into the United States must be accompanied by 

documentation giving a description of each animal from which specimen 

materials were taken including, if possible: 

1) Identification, age, size, sex, reproductive condition; 

NMFS Permit No. 932-1489-10 

Expiration Date: June 30,2009 
2) Date and location of collection; 

3) Circumstances causing the death; and 

4) The date and port of entry of each location. 

e. Any marine mammal part imported under the authority of this scientific 

research permit must not have been obtained as the result of a lethal taking 

that would be inconsistent with the Acts, unless specifically authorized in 

writing by the Office Director. 

f. The Permit HolderIPI must maintain records of the types, species, and 

numbers of specimens imported or exported, the importing or exporting 

country for each shipment, and circumstances surrounding the specimen 

acquisition (i.e., stranding, subsistence harvest, etc.). 

g. All specimen materials obtained under this authority shall be maintained 

according to accepted curatorial standards. 

h. Designated Ports of Entry: The USFWS Customs ports of entry (see 

Attachment A) are designated for the importation or exportation of wildlife 

and are referred to hereafter as "designated ports" (50 CFR 14.12). Please 

notify the USFWS wildlife inspectors at these ports at least 48 hours prior to 

import or export. 

To use a port of entry other than the designated ports listed in Attachment A, 

Researchers must obtain a Designated Port Exception Permit from the 

USFWS as required in 50 CFR 14.31 and 14.32. Additional information 

may be obtained from the USFWS website. http:llpeimits.fws.~~ovl. 

6. DISPOSITION OF PARTS 

a. After completion of initial research goals, Researchers must deposit any 

remaining samples or specimens into a bonafide scientific collection that 

meets the minimum standards of collection, curation, and data cataloging as 

established by the scientific community. 

b. Researchers may dispose of carcasses, skeletal material, and soft parts from 

marine mammals and endangered species, as deemed appropriate and as 

limited by the MMPA, ESA, and FSA. 

NMFS Permit No. 932-1489-10 

Expiration Date: June 30, 2009 
7. Transfer of Specimens (50 CFR 2 16.37): Marine mammal and endangered species 

parts taken or imported under authority of this permit may be transferred by the 

Permit HolderPI or CI(s) provided: 

a. Marine mammal parts, including cell lines, are not bought or sold. 

b. Specimens are transferred for research [including analysis, diagnostics and 

archival in a laboratory], maintenance in a scientific collection, or for 

education2 purposes. 

c. Recipients of marine mammal parts adhere to the Terms and Conditions of 

this permit, regulations at 50 CFR 216.37, and any additional conditions 

required by the Permit HolderIPI. 

d. Recipients of cell lines are designated as CIS under this permit or are holders 

of a special exception permit for scientific research and/or enhancement 

activities that includes development or research on cell lines, of the same 

species of marine mammal and/or endangered species. 

8. The authority of this permit will extend from the date of issuance through June 30, 

2009. The Terms and Conditions of the permit will remain in effect as long as the 

Researchers maintain the authority and responsibility of the marine mammal 

specimens collected, received, or imported hereunder. Attached is section 216.37 

of the Regulations Governing the Taking and Importing of Marine Mammals that 

contains additional conditions applicable to maintaining marine mammal parts. 

These regulations are made a part hereof. 

Notifications/Coordination [50 CFR 2 16.361 

1. The Permit HolderPI or CIS must notify the appropriate NMFS Assistant Regional 

Administrator for Protected Resources (see Attachment C) regarding events 

occurring in that Region. This notification must include (when possible) a 

description of the proposed activity, location, dates, and duration of activities. 

2. If the events occur within the boundaries of a National Marine Sanctuary, the 

Permit HolderPI or CIS must notify the Sanctuary Manager at the appropriate 

Sanctuary Office listed in Attachment C. When possible, this notification must 

include specific dates, locations, and participants involved in the activities. 

2 In the case of transfers for educational purposes the recipient must be a museum or educational institution or 

equivalent that will ensure that the part is available to the public as part of an educational program. 

NMFS Permit No. 932-1489-10 

Expiration Date: June 30, 2009 
3. To the maximum extent practical, the Permit Holder must coordinate permitted 

activities with activities of other Permit Holders conducting the same or similar 

activities on the same species, in the same locations, or at the same times of year to 

avoid unnecessary disturbance of animals. The appropriate Regional Office may be 

contacted (see Attachment C) for information about coordinating with other Permit 

Holders. 

D. Reporting Conditions [50 CFR 21 6.381 

1. ANNUAL REPORT 

Each year the permit is valid, the Permit HolderIPI must submit an annual report of 

research by March 3 1 of each year. The report shall cover research conducted 

during the previous year ending December 3 1 and describe the specific activities 

that have been conducted. For each marine mammal part taken, imported, exported 

or otherwise affected pursuant to permitted activities, the annual report must 

include the following: 

a. Carcasseslparts: 

1) A description of the part and its assigned identification number; 

2) Source, collector, country of origin, and authorizing government 

agency (for imported samples) for each sample reported; 

3) A summary of the research analysis conducted on the samples; and 

4) A description of the disposition of any marine mammal parts, 

including an identification of the part as required 921 6.37(a)(4) and 

the manner of disposition. 

b. Live animal activities: 

A description of the species, numbers of animals, locations of activities, and 

types of activities for: 

1) Live captures; 

2) Stranding response/disentanglement of marine mammals and 

endangeredlthreatened species; 

3) Specimen collections; 

4) Euthanasia (including reason for euthanasia, drugs used, etc.); and 

NMFS Pennit No. 932-1489-10 

Expiration Date: June 30,2009 
5) Incidental harassment during aerial surveys and land activities. 

Please also describe the animals' reactions to any of the above activities. 

2. FINAL REPORT 

Upon completion of the research, the Permit HolderIPI must submit a final report 

within 180 days of the last annual report. A final report should include information 

requested in 1 above, and: 

a. A summary of research objectives and results of research as it relates to the 

objectives; and 

b. An indication as to when and where the research results will be published 

3. Researchers must submit all reports and any papers or manuscripts published as a 

result of the research authorized herein, to the Director, Office of Protected 

Resources, NMFS, 13 15 East-West Hwy., Silver Spring, Maryland 2091 0. 

E. Photo,qaphy/Filming Restrictions [50 CFR 216.361 

1. Researchers working under this permit must obtain prior approval by the Permits 

Division for the following: 

a. Non-research related (i.e., commercial) use of photographs, video andlor 

film that were taken to achieve the research objectives; and 

b. All activities not essential to achieving the research objectives (e.g., still 

photography, videotaping, motion picture film making). Such activities 

must not influence the conduct of research in any way. 

2. Researchers are hereby notified that failure to obtain NMFS approval prior to 

conducting or facilitating such activities will be considered a violation of the 

permit. The Permit HolderPI and Researchers must agree, upon request by NMFS, 

to make space available on the vessel or aircraft for a NMFS observer during any 

trips where activities identified in E. 1 .b. may be conducted. 

3. Any commercial/documentary film approved for use must include a credit, 

acknowledgment, or caption indicating that the research was conducted under a 

permit issued by NMFS under the authority of the MMPA and/or the ESA. 

NMFS Permit No. 932-1489-10 

Expiration Date: June 30,2009 
1. The Permit HolderIPI is ultimately responsible for all activities of any individual 

who is operating under the authority of the permit. 

Co-investigators (CIS): The PI may designate additional CIS, provided that a copy 

of the letter designating the individual to conduct the activities authorized herein, 

and a copy of the individual's curriculum vitae is provided to the Permits Division 

by facsimile on the day of designation and confirmed by mail. The PI must ensure 

that the letter designating the individual(s) contains specific restrictions and a copy 

of the permit is attached to the designation letter. 

2. Research Assistants are individuals who work under the direct supervision of the PI 

or CI(s) and who are authorized, for example, to record data, serve as safety 

observers and boat tenders, or handle and process samples. 

a. Restrictions: Underwater observations and/or photography and operation of 

vessels may only be performed by personnel with documented experience 

(e.g., professional and/or experienced photographerslvideographers or 

licensed and/or experienced boat operators). 

b. Photo,qapher/video napher: A professional and/or experienced 

videographerlphotographer under the direct, on-site supervision of the 

Researchers may conduct activities requiring underwater observations 

and/or photography. The Permit HolderPI or CI(s) must be present at all 

times when activities are being conducted. 

3. Individuals conducting activities authorized under the permit must possess 

qualifications commensurate with hidher duties and responsibilities, or must work 

under the direct supervision of the PI or CI. 

4. Persons who require state, Federal, or foreign licenses to conduct activities 

authorized under the permit must be duly licensed when undertaking such activities. 

5. The Permit Holder cannot transfer or assign the permit to any other person. If the 

Permit Holder requests authorization to add a person to this permit, the Permit 

Holder cannot require compensation from the individual, in exchange for this 

request. 

6. The Permit Holder and all other persons operating under the authority of this permit 

must possess a copy of the permit when engaged in a permitted activity, when a 

marine mammal is in transit incidental to such activity, and whenever marine 

mammals or marine mammal parts are in the possession of such persons. A 

duplicate copy of this permit must be attached to the container, package, enclosure, 

NMFS Pennit No. 932-1489-10 

Expiration Date: June 30,2009 
or other means of containment, in which the marine mammals or marine mammal 

parts are placed for purposes of storage, transit, supervision, or care. 

Activities conducted by the United States Coast Guard personnel authorized as CoInvestigators, LANTAREA will keep a copy of the permit on file for reference 

landside at each of the following in Districts 1, 5,7, and 8: General Counsel offices, 

OPCON, each Station/Group/Activities office; and at the Offices of Law 

Enforcement. LANTAREA will also advise vessels 87' and greater to keep a copy 

of the permit on board. 

7. Inspection: Upon request by NMFS personnel or agents designated by the Director, 

Office of Protected Resources, the Permit Holder must make available for 

inspection, any records collected under authority of this permit. 

8. Permit Amendments: The Director, Office of Protected Resources, NMFS, may 

amend the provisions of this permit upon reasonable notice. 

9. No remuneration, either financial or in-kind, may be offered for the taking of 

animals from the wild. This does not preclude the payment of legitimate collection 

and transportation expenses (e.g., hiring staff, freight costs). It does, however, 

apply to paying bounties or incentive pay for the removal of animals from the wild. 

1 1. Any falsification of information pertaining to the permitted activities, including 

information provided to NOAA personnel, will be considered a violation of the 

permit. 

12. The Permit HolderIPI, in signing this permit, has accepted and will comply with the 

provisions of this permit, applicable Regulations (50 CFR parts 216 and 222-226), 

and the MMPA, ESA, and FSA. 

NMFS Permit No. 932-1489-10 

Expiration Date: June 30,2009 
G. Penalties and Permit Sanctions (50 CFR 216.40) 

1. Any person who violates any provision of this permit is subject to civil and criminal 

penalties, permit sanctions, and forfeiture as authorized under the MMPA, ESA and 

15 CFR part 904 [Civil Procedures] and 50 CFR part 1 1. 

2. All permits are subject to suspension, revocation, modification, and denial in 

accordance with the provisions of subpart D [Permit Sanctions and Denials] of 15 

CFR part 904 and 50 CFR part 13. 

JUN 2 2008 

Date 

Office of Protected Resources 

National Marine Fisheries Service 

Teri Rowles, Ph.D., D.V.M. Date 

Responsible PartyIPrincipal Investigator 

Marine Mammal Health and Stranding 

Response Program 

Office of Protected Resources 

National Marine Fisheries Service 

NMFS Permit No. 932-1489-10 

Expiration Date: June 30,2009 
Attachment A: U.S. Fish and Wildlife Service Wildlife h~spectors, Division of Law Enforcement 

DESIGNATED PORTS 

I 

Anchorage 

P.O. Box 190045 

Anchorage, Alaska, USA 995 19 

Phone: (907) 27 1-6 198 

Fax: (907) 271-6199 

Los Angeles 

370 Amapola Ave. #I14 

Torrance, California 9050 1 

Phone: (3 10)328-6307 

Fax: (3 10)328-6399 

Atlanta 

P.O. Box 45287 

Atlanta, Georgia 30320 

Phone: (404)763-7959 

Fax: (404)763-7560 

Miami 

10426 N.W. 3 1" Terrace 

Miami, Florida 33 172 

Phone: (305)526-26 10 

Fax: (305)526-2695 

Baltimore 

40 S. Gay Street, #223 

Baltimore, Maryland 2 1202 

Phone: (410)865-2127 

Fax: (410)865-2129 

New Orleans 

2424 Edenborn, Room 100 

Metairie, Louisiana 70001 

Phone: (504)2 19-8870 

Fax: (504)2 19-8868 

Boston 

70 Everett Avenue, Suite 3 15 

Chelsea, Massachusetts 02150 

Phone: (61 7)892-66 16 

Fax: (61 7)889-1980 

New York 

70 E. Sunrise Hwy. #419 

Valley Stream, New York 11580 

Phone: (5 16)825-3950 

Fax: (5 16)825-1929 - Inspectors 

Fax: (5 16)825-3 597 - Special Agents 

Chicago 

Wildlife Inspection Program 

P.O. Box 66726 

Chicago, Illinois 60666-0726 

Phone: (773)894-2910 

Fax: (773)894-2916 

Newark 

121 0 Corbin St. 

SeaLand Bldg., 2nd F1. 

Elizabeth, New Jersey 0720 1 

Phone: (973)645-6171 

Fax: (973)645-6533 

DallasEt. Worth 

17 17 West 23rd, Suite 104 

DFW Airport, Texas 7526 1 

Phone: (972)574-3254 

Fax: (972)574-4669 

Portland 

7000 NE Airport Way, Rrn. C2732 

Portland, Oregon 97238 

Phone: (503)23 1-61 35 

Fax: (503)23 1-6 133 

NMFS Permit No. 932-1489-10 

Expiration Date: June 30,2009 
Honolulu 

3375 Koapaka St., #F275 

Honolulu, Hawaii 968 19 

Phone: (808)86 1-8525 

Fax: (808)861-85 15 

San Francisco 

1633 Old Bayshore Hwy., Ste. 248 

Burlingame, California 9401 0 

Phone: (650)876-9078 

Fax: (650)876-9701 

2580 South 156~~ Street 

Blaine 

9925 Pacific Highway 

Blaine, Washington 98230 

Phone: (360)332-5388 

Fax: (360)332-3010 

Great Falls 

2800 Terminal Dr. 

Suite #I05 

Great Falls, Montana, USA 59404 

Phone: (406) 453-5790 

Fax: (406) 453-3657 

Brownsville 

1500 E. Elizabeth St. #239 

Brownsville, Texas 78520 

Phone: (956)504-2035 

Fax: (956)504-2289 

Nogales 

9 N. Grand Avenue #2229 A 

Nogales, Arizona 8562 1 

Phone: (520)287-4633 

Fax: (520)287-3877 

Detroit 

Bldg. 830 

2599 World Gateway Place 

Detroit Metro Airport, Michigan, USA 48242 

Phone: (734) 247-6800 

Fax: (734) 247-6805 

Buffalo 

405 N. French Road #I20 B 

Arnherst, New York 14228 

Phone: (71 6)691-3635 

Fax: (716)691-3990 

Puerto Rico 

65 1 FED. Dr. Suite 372-12 

Guaynabo, PR 00965 

Phone: (787) 749-4338 

Fax: (787) 749-4340 

Laredo 

Convent & Zaragoza 

Bridge #1,200.9 

Laredo, Texas 78040 

Phone: (956)726-2234 

Fax: (956)726-3718 

- - 

3~he USFWS Law Enforcement Division MUST authorize ALL non-designated port usage. If you prefer to 

use a non-designated port, please contact the appropriate Law Enforcement Office. 

NMFS Permit No. 932-1489-10 

Expiration Date: June 30,2009 
NMFS Permit No. 932-1489-10 

Expiration Date: June 30,2009 

Dunsieth 

RR1, Box 115 

Dunseith, North Dakota, USA 58329 

Phone: (701) 263-4462 

Fax: (701) 263-4463 

El Paso 

Bota, 3600 E. Paisano, #142A 

El Paso, Texas 79905 

Phone: (91 5) 872-4765 

Fax: (91 5)532-4776 

Guam 

41 5 Chalan San Antonio Road 

Baltej Pavillion, Suite 209 

Tarnuning, Guam 969 13-3620 

Phone: (67 1) 647-6064 

Fax: (671) 647-6068 

San Diego 

1 85 West F Street, Room 440 

San Diego, California 92101 

Phone: (61 9)557-5794 

Fax: (619)557-2997 

Tampa 

9549 Koger Blvd. #l 1 1 

St. Petersburg, Florida 33702 

Phone: (727)570-5398 

Fax: (727)570-5450 

St. PaulIMinneapolis 

HHH Terminal 

7 100 34th Avenue S. 

Minneapolis, Minnesota 55450 

Phone: (61 2)726-6302 

Fax: (61 2)726-6303 
Attachment B: 50 CFR $21 6.37 Marine mammal parts 

With respect to marine mammal parts acquired by take or import authorized under a permit issued 

under this subpart: 

(a) Marine mammal parts are transferrable if: 

(1) The person transferring the part receives no remuneration of any kind for the marine 

mammal part; 

(2) The person receiving the marine mammal part is: 

(i) An employee of NMFS, the U.S. Fish and Wildlife Service, or any other 

governmental agency with conservation and management responsibilities, who 

receives the part in the course of their official duties; 

(ii) A holder of a special exception permit which authorizes the take, import, or 

other activity involving the possession of a marine mammal part of the same species 

as the subject part; or 

(iii) In the case of marine mammal parts from a species that is not depleted, 

endangered or threatened, a person who is authorized under section 1 12(c) of the 

MMPA and subpart C of this part to take or import marine mammals or marine 

mammal parts; 

(iv) Any other person specifically authorized by the Regional Director, consistent 

with the requirements of paragraphs (a)(l) and (a)(3) through (6) of this section. 

(3) The marine mammal part is transferred for the purpose of scientific research, 

maintenance in a properly curated, professionally accredited scientific collection, or 

education, provided that, for transfers for educational purposes, the recipient is a museum, 

educational institution or equivalent that will ensure that the part is available to the public 

as part of an educational program; 

(4) A unique number assigned by the permit holder is marked on or affixed to the marine 

mammal part or container; 

(5) The person receiving the marine mammal part agrees that, as a condition of receipt, 

subsequent transfers may only occur subject to the provisions of paragraph (a) of this 

section; and 

(6) Within 30 days after the transfer, the person transferring the marine mammal part 

notifies the Regional Director of the transfer, including a description of the part, the person 

to whom the part was transferred, the purpose of the transfer, certification that the recipient 

has agreed to comply with the requirements of paragraph (a) of this section for subsequent 

transfers, and, if applicable, the recipient's pennit number. 

NMFS Permit No. 932-1489-10 

Expiration Date: June 30,2009 
(b) Marine mammal parts may be loaned to another person for a purpose described in paragraph 

(a)(3) of this section and without the agreement and notification required under paragraphs (a)(5) 

and (6) of this section, if: 

(1) A record of the loan is maintained; and 

(2) The loan is for not more than one year. Loans for a period greater than 12 months, 

including loan extensions or renewals, require notification of the Regional Director under 

paragraph (a)(6). 

(c) Unless other disposition is specified in the permit, a holder of a special exception permit may 

retain marine mammal parts not destroyed or otherwise disposed of during or after a scientific 

research or enhancement activity, if such marine mammal parts are: 

(1) Maintained as part of a properly curated, professionally accredited collection; or 

(2) Made available for purposes of scientific research or enhancement at the request of the 

Office Director. 

(d) Marine mammal parts may be exported and subsequently reimported by a permit holder or 

subsequent authorized recipient, for the purpose of scientific research, maintenance in a properly 

curated, professionally accredited scientific collection, or education, provided that: 

(1) The permit holder or other person receives no remuneration for the marine mammal 

part; 

(2) A unique number assigned by the permit holder is marked on or affixed to the marine 

mammal specimen or container; 

(3) The marine mammal part is exported or reimported in compliance with all applicable 

domestic and foreign laws; 

(4) If exported or reimported for educational purposes, the recipient is a museum, 

educational institution, or equivalent that will ensure that the part is available to the public 

as part of an educational program; and 

(5) Special reports are submitted within 30 days after both export and reimport as required 

by the Office Director under 5216.38. 

NMFS Permit No. 932-1489-10 

Expiration Date: June 30,2009 
Attachment C: Relevant Addresses 

NMFS Regional Offices 

Assistant Regional Administrator for Protected Resources, Northwest Region, NMFS, 7600 

Sand Point Way NE, BIN C 15700, Bldg. 1, Seattle, WA 98 1 15-0700; phone (206) 526- 

6150; fax (206) 526-6426. 

Assistant Regional Administrator for Protected Resources, Alaska Region, NMFS, P.O. 

Box 21668, Juneau, AK 99802-1668; phone (907) 586-7235; fax (907) 586-7012. 

Assistant Regional Administrator for Protected Resources, Southwest Region, NMFS, 501 

West Ocean Blvd., Suite 4200, Long Beach, CA 90802-42 13; phone (562) 980-4020; fax 

(562) 980-4027. 

Assistant Regional Administrator for Protected Resources, Pacific Islands Regional Office, 

NMFS, 1601 Kapiolani Blvd., Suite 1 1 10, Honolulu, HI 968 14-4700; phone (808) 973- 

2935; fax (808) 973-2941. 

Assistant Regional Administrator for Protected Resources, Northeast Region, NMFS, One 

Blackbum Drive, Gloucester, MA 01930-2298; phone (978) 281-9346; fax (978) 281 -9371. 

Assistant Regional Administrator for Protected Resources, Southeast Region, NMFS, 263 

Avenue South, St. Petersburg, FL 33701; phone (727) 824-5312; fax (727) 824-5309. 

NOS National Marine Sanctuaries 

Channel Islands National Marine Sanctuary, 113 Harbor Way, Santa Barbara, CA 93 109; 

phone (805) 966-7 107. 

Cordell Bank National Marine Sanctuary, Fort Mason, Building #201, San Francisco, CA 

94123; phone (415) 561-6622. 

Fagatele Bay National Marine Sanctuary, P.O. Box 43 18, Pago Pago, AS 96799; phone 

(01 1-684) 633-7354. 

Florida Keys National Marine Sanctuary, P.O. Box 500368, Marathon, FL 33050; phone 

(305) 743-2437. 

Florida Keys National Marine Sanctuary (Lower Region), 21 6 Ann Street, Key West, FL 

33040; phone (305) 292-03 1 1. 

Florida Keys National Marine Sanctuary (Upper Region), P.O. Box 1083, Key Largo, FL 

33037; phone (305) 852-7717. 

NMFS Permit No. 932-1489-10 

Expiration Date: June 30,2009 
Flower Garden Banks National Marine Sanctuary, 216 W. 26th Street, Suite 104, Bryan, TX 

77803; phone (409) 779-2705. 

Gray's Reef National Marine Sanctuary, 10 Ocean Science Circle, Savannah, GA 3 141 1; 

phone (912) 598-2345. 

Gulf of the Farallones and Cordell Bank National Marine Sanctuaries, Fort Mason, 

Building 201, San Francisco, CA 94123; phone (415) 561-6622. 

Hawaiian Islands Humpback Whale National Marine Sanctuary, 726 South Kihei Road, 

Kihei, HI 96753; phone (808) 879-281 8. 

Monitor National Marine Sanctuary, The Mariners' Museum, 100 Museum Drive, Newport 

News, VA 23606-3759; phone (757) 599-3 122. 

Monterey Bay National Marine Sanctuary, 299 Foam Street, Suite D, Monterey, CA 

93940; phone (408) 647-4258. 

Olympic Coast National Marine Sanctuary, 13 8 W. lSt Street, Port Angeles, WA 98362; 

phone (360) 457-6622. 

Stellwagen Bank National Marine Sanctuary, 14 Union Street, Plymouth, MA 02360; 

phone (508) 747- 1691. 

US Fish and Wildlife Service 

Sirenia (other than Florida manatee) - Office of Management Authority, 4401 N. Fairfax 

Drive, Arlington, VA 22203; phone (800) 358-2 104. 

Florida manatee - Field Supervisor, Jacksonville Field Office, 6620 South Point Drive 

South, Suite 310, Jacksonville, FL 32216-0312; phone (904) 232-2580; fax (904) 232- 

2404. 

Southern sea otter - Field Supervisor, Ventura Field Office, 2493 Portola Road, Suite B, 

Ventura, CA 93003; phone (805) 644-1766; fax (805) 644-3958. 

Northern sea otter, walrus, polar bear - Marine Mammals Management, 1 101 E. Tudor 

Road, Anchorage, AK 99503-6199; phone (907) 786-3800; fax (907) 786-381 6. 

NMFS Pennit No. 932-1489-10 

Expiration Date: June 30,2009 
APPENDIX H 

GENERAL DESCRIPTIONS OF RESEARCH METHODOLOGIES 

UNDER THE ESA/MMPA PERMIT

H-1

Many public comments on the draft PEIS were specific to the methodologies addressed in this 

Appendix. In several areas, revisions were included below. For more specifics on how public 

comments were addressed, please refer to Appendix N of this PEIS. 

1. Current ESA/MMPA Permit Activities 

The activities described in this Section are those that may be conducted under the current 

ESA/MMPA permit issued to the Marine Mammal Health and Stranding Response Program. Many 

of the activities are only applicable to the scientific research conducted by Co-Investigators under the 

permit. Some activities are also applicable to the emergency response of ESA-listed species, which is 

covered under the ESA/MMPA permit. This section does not include information on basic stranding 

response activities. 

1.1.1 Close Approach 

Animals may be taken through close approaches by aircraft for disentanglement, photo-identification, 

behavioral observation, hazing (during emergency response), and incidental harassment. Animals 

may be taken through close approaches by vessel for disentanglement, photo-identification, 

behavioral observation, capture, tagging, marking, biopsy sampling, skin scrapes, swabs, collection of 

sloughed skin and feces, breath sampling, blood sampling, administration of drugs, video recording, 

hazing (during emergency response), and incidental harassment. More than one vessel may be 

involved in close approaches and vessels may approach an animal more than once, in order to 

complete research tasks. Incidental harassment of non-target animals may occur during close 

approaches by aircraft or vessel. During emergency response and research activities, close 

approaches may occur for any age class, sex, and species (including ESA-listed species). 

1.1.2 Aerial Surveys 

Aerial surveys are used to: locate imperiled marine mammals (ESA-listed and non-listed species); 

monitor behavior or disease in a given population or individual; survey the extent of disease 

outbreaks or die-offs; and locate carcasses. During emergency response and research activities, aerial 

surveys may occur for any age class, sex, and species (including ESA-listed species). 

The aircraft type used during emergency response activities depends upon the aircraft available at the 

time of the response and the logistics of the activity. Aircraft type includes helicopters and fixedwing aircraft. The frequency of surveys is dependent on the circumstances of the involved stranded 

or entangled animals, the disease, or the occurrence of an Unusual Mortality Event (UME). Aerial 
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surveys are flown along predetermined transect lines at a set altitude and air speed while observers 

scan the water for signs of marine mammals. 

The speed and altitude of the aircraft depends on the aircraft and the response or research situation. 

For large cetaceans, surveys would be flown at an altitude of 230-300 m (750-1,000 ft) at 

approximately 110 knots (203 km/hr). For right whales, surveys would be flown at 100 knots (185 

km/hr). For smaller cetaceans, surveys would be flown at an altitude of approximately of 230 m (750 

ft). Large survey aircraft would be flown at 110 knots (203 km/hr) and small aircraft would be flown 

at 97 knots (179 km/hr). When an animal or group of animals is sighted, the survey aircraft descends 

and circles over the animal or animals to obtain photographs and assess the animal, if necessary. 

A minimum altitude of 153 m (500 ft) would be used for pinniped surveys. The typical altitude 

would be between 182-244 m (600-800 ft) at 80 to 100 knots (148-185 km/hr). For Steller sea lion 

surveys during the breeding season, an altitude of at least 214 m (700 ft) would be used to collect 

photographs. In the non-breading season, surveys would be flown between 150-200 m (492-655 ft) at 

a speed of 100-150 knots (185-278 km/hr). All aerial surveys will be flown according to the NOAA 

Aviation Safety Policy (NOAA Administrative Order 209-124), with trained observers and pilots. 

1.1.3 Vessel Surveys 

Vessel surveys of both ESA-listed and non-listed marine mammals may be conducted to: collect data 

on animal abundance; assess animals; locate animals for research activities; and collect research 

samples. The vessels themselves may be used as a platform for conducting animal sampling. Vessel 

surveys may be used to monitor animals subsequent to capture-release sampling for assessment, 

photo-identification, and tracking. 

For small cetaceans, inshore monitoring surveys are conducted using small (5-7 m) outboard motor 

powered boats. Animals are located by having crew members visually search waters as the boat 

proceeds along a specified route at slow speeds (8-16 km/hr). Animals outfitted with Very High 

Frequency (VHF) radio tags are located by listening for the appropriate frequency and, after detecting 

a signal, maneuvering the boat towards the animal using a combination of signal strength and 

directional bearings. Frequencies and remote sensors may also be monitored. Once a group of 

animals is located, the boat approaches the group so that crew members can assess their physical and 

medical condition. Photographs of the dorsal fins of individual animals are taken for later 

identification and matching to existing dorsal fin catalogs. When an animal is located that has been 

recently caught for a health evaluation, an attempt is made to photograph the dorsal fin and body to 
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confirm identification, health, position, and behavior. A photograph of the dorsal fin would also be 

used to assess wound healing from tag attachment. The area behind and below the posterior aspect of 

the dorsal fin may also be photographed to assess biopsy wound healing. A telephoto lens would be 

used for photographs, so vessels would not need to be too close to animals. 

Multiple approaches may be required to obtain appropriate quality photographs, particularly if there 

are multiple individuals within a group. Close approach is terminated and the boat moves away from 

the group if animals begin to display behavior that indicates undue stress (e.g., significant avoidance 

behavior such as chuffing [forced exhalation], tail slapping, or erratic surfacing). 

1.1.4 Hazing 

Hazing of ESA-listed marine mammals may occur if an animal is in the vicinity of an oil or 

hazardous material spill, harmful algal bloom, sonar, or other harmful situations. Animals may also 

be hazed to deter a potential mass stranding. For all marine mammals, including threatened and 

endangered species, hazing is authorized under the MMHSRP’s MMPA/ESA permit. Hazing 

methods include, but are not limited to, the use of acoustic deterrent devices, acoustic harassment 

devices, visual deterrents, vessels, physical barriers, and capture and relocation. The correct use of 

deterrents incorporates the element of surprise, while minimizing the potential for habituation. 

Acoustic deterrents that may be used to deter cetaceans include, but are not limited to: pingers, bubble 

curtains, Oikomi pipes, acoustic harassment devices (e.g., Airmar devices), seal bombs, airguns, midfrequency sonar, low-frequency sonar, predator calls, and aircraft. Pingers, which are typically used 

in the commercial fishing industry, produce high-frequency pulses of sound to deter animals. The 

standard pinger emits a signal of 10 kHz (with harmonics to at least 60 kHz) with a source level of 

132 dB re μPa at 1 m, which is within the hearing range of most cetaceans (Reeves et al. 1996). 

Bubble curtains may be used as a barrier from other acoustics. Oikomi pipes are banged together by 

personnel on boats. They have been effective in herding cetaceans, but may not be as effective in 

keeping animals out of a large area. 

Airmar devices have a source level of 195 dB re μPa and their peak energy is at 10 kHz with higher 

harmonics. These devices may be moved at low speeds on small boats or may be hull mounted on 

boats to allow faster movement. They may be able deter animals 3 km away. A line of directional 

Airmar devices could be deployed at the sight of a spill of near cetaceans to move them away. The 

received levels needed to cause deterrence without acoustic trauma are unknown. 
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Seal bombs are explosive devices that are weighted with sand to sink and explode at 2-3 m 

underwater, producing a flash of light and an acoustic signal of less than 2 kHz and a source level of 

approximately 190 dB. The noise and light would potentially startle marine mammals, but not cause 

any injuries (Petras 2003). Airguns are generally a towed array that is deployed behind a ship. Their 

peak energy is dependent on size, and may range from 10 Hz to 1 kHz. Airguns produce broadband 

pulses with energy at frequencies ranging over 100 kHz. The higher frequencies are less intense and 

attenuate faster. Harbor porpoise have been seen moving away from airguns 70 km away. 

Mid-frequency sonar may be used to deter cetaceans. It has caused deterrence in killer whales in 

Haro Strait during the 2003 USS Shoup transit episode. The sonar had a source level of 

approximately 235 dB (exact level is classified) and the frequency ranged from 2.6-3.3 kHz over 1-2 

second signals emitted every 28 seconds (USN 2004). Mid-frequency sonar could be effective over 

25 km, which would be important for deterring animals during a large oil spill. Low-frequency sonar 

may also be used, but may too low for some cetaceans to hear. 

Predator calls (typically killer whale calls) may be played to deter potential prey. However, in most 

situations, predator calls have proven ineffective in changing prey behavior. Aircraft, such as 

helicopters, generate a fair amount of noise and wave movement at close range and could produce a 

startle or avoidance response. This may be effective initially, but animals would likely habituate 

quickly. Aircraft could also be used to deploy seal bombs, if necessary. Vessels may be used to herd 

animals back out to open water or away from a hazardous situation. Booms or line on the water may 

be used to displace small odontocetes from stranding. Fire hoses may be used at close range as a 

physical deterrent, although their effectiveness is not known. 

Pinniped acoustic deterrents include seal bombs, Airmar devices, predator calls, bells, firecrackers, 

and starter pistols. Visual deterrents for pinnipeds include flags, streamers, and flashing lights. 

Exclusion devices for pinnipeds may include nets or fencing. 

1.1.5 Capture and Restraint 

Capture of marine mammals may be necessary during research and enhancement activities to collect 

specimens; perform an examination; evaluate wound, disease, entanglement, or injury; or attach tags 

and/or scientific instruments. Capture of non-ESA listed marine mammals would be necessary during 

research activities. During emergency response, these activities may occur for any age class, sex, and 

species (including ESA-listed species). For research activities, capture, restraint, and handling would 

occur on all animals except for young of the year. 
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Capture methods include, but are not limited to, nets, traps, behavioral conditioning, and 

anesthesia/chemical immobilization. These procedures would be performed or directly supervised by 

qualified personnel and, if possible, an experienced marine mammal veterinarian would be present to 

carry out or provide direct on-site supervision of all activities involving the use of anesthesia and 

sedatives. Capture and restraint methods for pinnipeds and cetaceans are discussed below. 

1.1.5.1 Pinniped Capture and Restraint 

Capture and restraint of pinnipeds occurs during health assessment studies, emergency response, and 

disentanglement activities. Pinnipeds may be captured on land or in water by various methods, 

depending on the targeted age classes. On land, pups (>5 days to 2 months old) and juveniles (>2 

months to 3 years old) may be captured by hand. Juveniles and adults (>3 years old) may be captured 

using circle, hoop, dip, stretcher, and throw nets. Net guns and pole nooses may be used for capture 

of pinnipeds. An injectable immobilizing agent, administered remotely by a dart, may also be used to 

subdue older animals. Herding boards may be used to maneuver animals into cages. For water 

captures of pinnipeds, dip nets, large nets, modified gill nets, floating or water nets, and platform 

traps may be used. Purse seine nets may be used offshore of haul-out sites to capture animals when 

they stampede into the water (Jeffries et al. 1993). Animals become entangled by the net as it is 

pulled ashore. Once removed from the net, animals are placed head first into individual hoop nets. 

Pups may be restrained by hand, in a hoop net, or with the inhalation of a gas anesthesia 

(administered through a mask over their nose). Older animals may be restrained using gas anesthesia 

(administered through an endotracheal tube), a fabric restraining wrap, a restraining net, or through 

sedation (either intramuscular (IM) or intravenous (IV)). 

An animal would not be manually restrained for more than 30 minutes. Procedures would be 

conducted as quickly as possible to reduce stress on the animal. Vital signs, including respiration, 

heart rate, and temperature, would be continuously monitored and recorded at the start of handling 

and every 5 minutes thereafter. 

1.1.5.2 Cetacean Capture and Restraint 

Capture and restraint of cetaceans occurs during health assessment studies, emergency response, and 

disentanglement activities. Typical methods currently used during health assessment studies and for 

emergency response are described below. However, these methods may vary depending on the 

species and location. All capture and restraint protocols would be approved by NMFS PR1 before 

their use. For health assessment studies of small cetaceans, small schools of animals are approached 
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for identification (see description under vessel surveys). If the school contains animals desired for 

capture, the school is followed until it is in waters that facilitate safe captures (waters outside of 

boating channels, equal to or less than 1.5 m deep, where currents are minimal). Typically no more 

than three animals are captured at one time. The animals are encircled with a 600 m long by 4 m deep 

seine net, deployed at high speed from an 8 m long commercial fishing motor boat. Small (5-7 m) 

outboard-powered vessels are used to help contain the animals until the net circle is complete. These 

boats make small, high-speed circles, creating acoustic barriers. 

Once the net is completed, about 15-25 handlers are deployed around the outside of the corral to 

correct net overlays and aid any animals that may become entangled in the net. The remaining 10-20 

or more team members prepare for sampling and data collection and begin the process of isolating the 

first individual. Isolation is accomplished by pinching the net corral into several smaller corrals. 

Handlers are usually able to put their arms around the selected animal as it bobs in place or swims 

slowly around the restricted enclosure. However, a few animals may strike the net and become 

entangled. After animals are restrained by handlers, an initial evaluation is performed by a trained 

veterinarian. Once cleared by the veterinarian, the animal is transported to the processing boat via a 

navy mat and/or a sling. A sling is also used to place an animal back in the water for release. 

In some cases, cetaceans may need to be captured in deep waters. A break-away hoop-net is used to 

capture individuals as they ride at the bow of the boat. When they surface to breathe, the hoop is 

placed over their head and they move through the hoop, releasing the net. The additional drag of the 

net slows the animals substantially, but the design allows the animal to still use its flukes to reach the 

surface to breathe. The net is attached to a tether and large float, and the animal is retrieved, 

maneuvered into a sling and brought onboard the capture boat. 

For emergency response, small cetaceans in shallow water may be caught using a net deployed from a 

boat with methods similar to those described above. In rivers and canals, responders may use their 

bodies to herd an animal and then hand catch it. In deep water, hoop net may be used to capture 

animals. 

1.1.6 Transport 

Vehicles, boats, or aircraft are used to transport marine mammals to rehabilitation facilities or release 

sites. Cetaceans may be transported on stretchers, foam pads, or air mattresses. For short-term 

transport, closed-cell foam pads are preferred because they are rigid and do not absorb water. Open 

cell foam is typically used for long-term transport of cetaceans because it can contour to the animal’s 
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form. Boxes may be constructed to transport the animal upright in a stretcher. Cetaceans must be 

protected from exhaust fumes, sun, heat, cold, and wind, as transport often occurs on the flatbed of a 

truck. Animals are kept moist and cool, to avoid overheating (Geraci and Lounsbury 2005). 

Small pinnipeds are typically transported in plastic kennel cages. Cages are large enough for animals 

to turn around, stretch out, and raise their heads. Cages should prevent animal contact with waste 

and allow proper air circulation. As with cetaceans, pinnipeds traveling by vehicle must be protected 

from the sun, heat, cold, wind, and exhaust fumes. Pinnipeds may overheat during transit and wetting 

the animal helps to prevent hyperthermia (Geraci and Lounsbury 2005). Large pinnipeds may need to 

be sedated during transport. Sedation of large pinnipeds would be performed or directly supervised 

by qualified personnel and, if possible, an experienced marine mammal veterinarian would be present 

to carry out or provide direct on-site supervision of all activities involving the use of sedatives. 

Transport procedures for marine mammals under U.S. jurisdiction follow the Animal and Plant 

Health Inspection Service’s “Specifications for the Humane Handling, Care, Treatment, and 

Transportation of Marine Mammals” (9 CFR Ch 1, Subpart E). The “Live Animal Regulations” 

published by the International Air Transport Association (IATA), and accepted by the Convention on 

International Trade in Endangered Species of Wild Fauna and Flora, are followed for the air transport 

of animals under foreign jurisdiction (IATA 2006). Both sets of standards have specifications for 

containers, food and water requirements, methods of handling, and care during transit. 

1.1.7 Tagging/Attachment of Scientific Instruments 

Tagging of ESA-listed marine mammals may be used to monitor an animal’s movements after 

immediate release (from a stranding site), release after rehabilitation, or release after research 

activities. Tagging of non-listed marine mammals may occur as part of a research project or for 

monitoring rehabilitated animals post-release when such tag devices are considered intrusive or 

experimental. Other tags or scientific instruments may be used to obtain data on dive depth, dive 

time, water temperature, light levels, and animal and other underwater sounds. During emergency 

response activities, tags or scientific instruments may be attached to any age class, sex, and species 

(including ESA-listed species). During research activities tags will not be attached to large cetacean 

calves less than six months of age or females accompanying such calves. For small cetaceans, no 

tagging will occur on calves less than one year of age. 

A variety tags (including scientific instruments) may be attached to or implanted in an animal. The 

type of tag and method of attachment depends on the species being tagged and the research or 
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question being addressed. Types of tags that are used include, but are not limited to: roto-tags (cattle 

tags), button tags, very high frequency (VHF) radio tags, satellite tags, Passive Integrated 

Transponder (PIT) tags, D-tags, code division multiple access (CDMA) tags, pill (e.g., stomach 

temperature telemeters), time-depth recorders (TDRs), life history transmitters (LHX tags), and 

crittercams (video cameras). Tag attachment methods vary with tag type, species, and circumstances. 

Attachment methods for cetaceans include, but are not limited to: bolt, buoy, punch, harness, suction 

cup, implant, or ingestion. Pinniped attachment methods include, but are not limited to: glue, bolt, 

punch, harness, suction cup, surgical implant, or ingestion. Specific tags and methods of attachment 

will be evaluated for each situation. 

1.1.7.1 Tagging of Cetaceans 

Tags are generally attached to free-swimming cetaceans by crossbow, compound bow, rifles, spear 

guns, slingshot (or throwing device), pole or jab spears. Tags will only be applied by experienced 

marine mammal biologists. Prior to deployment, tag type and attachment method will be approved by 

NMFS PR1. Attachments are temporary and occur via a suction cup device or implant. Scientific 

instruments attached to suction cups include, but are not limited to D-tags, TDRs, VHF tags, satellite 

tags, and crittercams. Large, slow moving whales may be tagged via suction cups using a pole 

delivery system, cantilevered on the bow of a boat. Bow-riding animals may be tagged using a hand 

held pole. Crossbows are the preferred method for tagging fast-moving toothed whales. Tags are 

attached on the dorsal surface of the animal behind the blowhole, closer to the dorsal fin. Tag 

placement ensures that the tag will not cover or obstruct the whale’s blowhole, even if the cup 

migrates after placement (movement would be toward the tail). 

Implantable tags may be attached in free-swimming cetaceans by mounting the instrument on an 

arrow tip or other device designed to penetrate the skin of the animal. Tags would typically be 

attached by crossbow and may include, but not limited to satellite tags, VHF tags, and TDRs. Buoys 

are used to attach VHF or satellite tags to gear on entangled whales. Buoys may also be attached to 

increase drag in an attempt to slow a whale for disentanglement. 

For animals in hand, tags may be attached for longer deployments. Roto-tags may be attached to 

cetaceans with a plastic pin to the trailing edge of the dorsal fin. Button tags are plastic disks attached 

with a bolt through the dorsal fin. VHF tags (roto-radio tags) may also be bolted through the trailing 

edge of the dorsal fin. The bolts on each type of tag are held in place by magnesium nuts that will 

corrode in seawater and allow the tag to be released. 
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Satellite or VHF tags can be mounted on a molded plastic or fabric saddle that would be bolted 

through the dorsal fin (Geraci and Lounsbury 2005) or dorsal ridge. Plastic saddles would be padded 

with foam on the inside to reduce skin irritation. Saddles will be attached to the dorsal fin with two or 

three Delrin pins secured with magnesium nuts. The nuts would corrode in seawater, allowing the 

package to be released within a few days or weeks. The saddle will be raised off the surface of the 

dorsal fin by inserting foam washers on the pins between the skin and saddle. Two washers would be 

used to provided approximately 6 mm of separation 

Dorsal ridge “spider tags” may be used on beluga whales (NMFS Permit No. 782-1719) (Litzky et al.

2001). Up to four holes are bored in the region of the anterior terminus of the dorsal ridge using a 

coring device (trochar) with a diameter of no more than 1 cm. Each insertion and exit point for the 

trochars would be prepared by cleaning with an antiseptic wipe, or equivalent. Rods of nylon or other 

non-reactive material, not greater than 1 cm in diameter and 50 cm in length, would then be pushed 

through the holes and attached to the wire cables or fabric flange or straps of the satellite tags or 

through bolt holes in the tag. The wire cables would be tightened to hold the tag against the back of 

the animal to minimize tag movement and drag, but would not be put under significant tension to 

avoid pressure necrosis around the pin insertion points. The other attachment systems would be 

manipulated to achieve the best possible fit depending on their design. Excess rod would then be cut 

off. All equipment would be sterilized in cold sterile solution, alcohol, or equivalent, and kept in airand water-tight containers prior to use. Trochars and rods would be coated with antiseptic gel prior to 

insertion and each trochar would only be used for one hole before it is cleaned, sharpened, and resterilized. Where more than one instrument is to be attached, the number of pins would be limited to 

four. 

1.1.7.2 Tagging of Pinnipeds 

A fast drying epoxy adhesive is used to glue scientific instruments to pinnipeds. Instruments may be 

attached to the dorsal surface, head, or flippers and will release when the animal molts. Roto-tags can 

be attached to flippers using a single plastic pin. Tags can also be surgically implanted into the body 

cavity or muscle of pinnipeds. Implanted tags include PIT and LHX tags. 

A PIT tag is a glass-encapsulated microchip, which is programmed with a unique identification code. 

When scanned with an appropriate device, the microchip transmits the code to the scanner, enabling 

the used to determine the exact identity of the tagged animal. PIT tags are biologically inert and are 

designed for SQ injection using a syringe or similar injecting device. The technology is well 
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established for use in fish and is being used successfully on sea otters (Thomas et al. 1987), manatees 

(Wright et al. 1998), and southern elephant seals (Galimberti et al. 2000). PIT tags are also 

commonly used to identify domestic animals. PIT tags may be injected just below the blubber in the 

lumbar area, approximately 5 inches lateral to the dorsal midline and approximately 5 inches anterior 

to the base of the tail. Tags may also be injected at alternative sites on a pinniped’s posterior, but 

only after veterinary consultation. The injection area would be cleansed with Betadine (or equivalent) 

and alcohol prior to PIT tag injection. PIT tags are currently being used in Hawaiian monk seals 

(NMFS Permit No. 848-1695). 

LHX tags are implantable, satellite-linked life history transmitters used to measure mortality events in 

pinnipeds. The tag allows continuous monitoring from up to five built-in sensors, including pressure, 

motion, light levels, temperature, and conductivity. The tag is surgically implanted into the 

abdominal cavity while the animal is anesthetized. An incision of 7-8 cm long through the abdominal 

wall, including abdominal muscles and peritoneal layers, is required to insert the tag. The incision is 

closed using absorbable sutures and may be further secured with surgical glue or dissolvable staples. 

When the animal dies, the tag is released from the body and floats to the surface or falls out onshore. 

Data from the tag is transmitted via the ARGOS system to a NOAA satellite. The battery life of an 

LHX tag is well over five years. LHX tags are being evaluated under current NMFS PR1 research 

permits (Permit No.1034-1685 [California sea lions] and No. 881-1890 [Steller sea lions]). 

1.1.8 Marking 

Marking methods for marine mammals during emergency response and research activities include, 

but are not limited to: bleach, crayon, zinc oxide, paint ball, notching, and freeze branding. Hot 

branding will not be used as a marking method. Crayons, zinc oxide, and paint balls can be used on 

cetaceans and pinnipeds for temporary, short-term marking. Bleach or dye (human hair dye) 

markings can be used on pinnipeds. The marks are temporary, with the length of time dependent on 

molting. Notching can be used to permanently mark cetaceans by cutting a piece from the trailing 

edge of the dorsal fin. Notching in pinnipeds removes a piece of skin from the hind flipper of phocids 

(true or earless seals) and the foreflipper of otariids (sea lions and fur seals). 

Cetaceans can be marked using freeze branding, typically on both sides of the dorsal fin and/or just 

below the dorsal fin. Freeze branding is used during health assessment studies to mark all animals for 

post-release monitoring. Freeze branding uses liquid nitrogen to destroy the pigment producing cells 

in skin. Each brand (typically 2" numerals) is supercooled in liquid nitrogen and applied to the dorsal 
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fin for 15-20 seconds. After the brand is removed, the area is wetted to return the skin temperature to 

normal. During health assessments, each animal is photographed and videotaped to record the 

locations of freeze brands. Brands will eventually re-pigment, but may remain readable for five years 

or more. Freeze brands provide long-term markings that may be important during subsequent 

observations for distinguishing between two animals with similar fin shapes of natural markings. 

Freeze branding may be used to produce two types of marks on pinnipeds. Short contact by the 

branding iron destroys pigment producing cells, leaving an unpigmented brand. Longer contact with 

the brand destroys these cells and the hair, leaving a bald brand (Merrick et al. 1996). Hot branding 

of pinnipeds will not be conducted during permit activities. 

1.1.9 Disentanglement 

Disentanglement efforts are conducted for many marine mammals. For large whales, 

disentanglement efforts may include vessel and aerial surveys for the affected animal and incidental 

harassment of non-entangled animals during these searches. Close approaches may occur to assess 

the extent of the entanglement and the health of the animal. The animal may be either physically or 

chemically restrained. Physical restraint of the animal may be used to slow down an animal, provide 

control, and maintain large whales at the surface. Physical restraint is accomplished by attaching 

control lines, floats, buoys, and/or sea anchors to the entangling gear with a grappling hook or by 

attaching new gear to the animal to hold it. The drag from small boats may also slow down an 

animal. Remote sedation may also be used to restrain the animal. Animals may be tagged with 

telemetry buoys to monitor their location. Responders use control lines to pull themselves up to the 

whale. Cutting of lines and possibly flesh (when the line is embedded) may occur during 

disentanglement. Biopsy sampling may occur, either through the use of a remote dart (described 

below under biopsy sampling) or the collection of tissues from the removed fishing gear. If the 

injuries from an entanglement appear to be life-threatening, the animal may be euthanized. NMFS 

and marine mammal experts would be consulted before deciding to euthanize a large whale. 

Euthanasia techniques are discussed later in this application. A necropsy would be performed and the 

carcass would be properly disposed. 

Disentanglement efforts for small cetaceans may include capture with incidental disturbance of nonentangled animals, restraint, surgery, rehabilitation, administration of chemical agents (sedatives 

and/or antibiotics), and release. Response to entangled small cetaceans typically requires in-water 

capture of free-swimming animals. Some animals may have impaired locomotion if the gear is heavy 
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or anchored. Capture methods for small cetaceans are described above. If the injuries from an 

entanglement appear to be life-threatening, the animal is not likely to make a recovery on its own, or 

if the animal is afflicted with a potentially treatable illness or infection, it may be placed in 

rehabilitation. If rehabilitation space is not available, the animal would be euthanized. A necropsy 

would be performed and the carcass would be properly disposed. 

An entangled pinniped would be selected for capture if: 1) the entanglement or injury impedes 

feeding, swimming, or ambulation; 2) the gear is unlikely to fall off on its own; 3) the animal is likely 

to “grow” into the gear, causing constriction; 4) the gear is cutting into the flesh or likely to cut into 

the flesh into the future; 5) the injury appears life-threatening or infected, or likely to become 

infected; or 6) the benefits of capturing and disentangling or collecting the animal for rehabilitation 

outweigh the risks to the animal and the herd. Entangled pinnipeds are typically captured on land 

when they are hauled out. Capture methods for pinnipeds are described above. 

Disentanglement of pinnipeds may be achieved by simply cutting off the gear. A variety of 

instruments, including shielded knives, bandage scissors, wire cutters, and dog nail clippers may be 

used to safely accomplish this task. For emergency situations (e.g., entangled animals anchored in the 

water) or if the situations allows, long-handled, shielded knives can be used to cut off netting from a 

distance. The attending veterinarian (or other qualified individual) will determine which 

instrument(s) is appropriate for the situation. Once the gear is removed, it is photographed, measured, 

and retained for submission to NMFS. The wound (if any) is cleaned thoroughly by flushing with 

copious amounts of an appropriate disinfectant and treated with a topical antiseptic cream. An animal 

may be freed of gear and immediately released, or brought into a rehabilitation facility for a period of 

time prior to release. Every disentangled animal (except those that are not restrained) are tagged 

with: a roto-tag on the rear flipper; a head tag glued to the fur or marked; and/or paint stick markings 

for post release monitoring. Satellite tags maybe considered for healthy animals, weighing 75 lbs or 

more, if supplies and experienced personnel are available. Methods for tagging are described above. 

If the pinniped will be immediately released after disentanglement, the following data will be 

collected (as feasible): straight length; sex; weight estimate; photographs of the animal, wound (if 

any), and gear; general locations; and GPS coordinates. Alert animals would be released from the 

original capture site unless conditions dictate otherwise. Animals would not be released near high 

drop-offs, heavy boat traffic, heavily human populated beaches, or obvious hazards. The attending 

veterinarian (or qualified individual) will direct the removal of restraint devices and withdrawal of the 

animal for a safe release. Crowder boards would be placed between the animal and the water, to 
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prevent the animal from fleeing into the water before the capture net has been removed. Once the 

animal has completely freed itself from the capture net, the crowder boards would be opened to allow 

access to the water. The animal would retreat to the water at is own pace. 

An animal may be placed into rehabilitation if the injuries appear to be life-threatening, it is not likely 

to make a recovery on its own, or if it is afflicted with a potentially treatable illness or infection. 

Transport methods are described above. If rehabilitation space is not available, the animal would be 

euthanized. A necropsy would be performed and the carcass would be properly disposed. 

1.1.10 Sample Collection and Analysis 

Specimen samples would be taken from ESA-listed species during both research and enhancement 

(i.e., stranding/entanglement response) and from non-listed species during intrusive research [the 

Order Cetacea and the Order Pinnipedia (except walrus)]. Specimen materials may include, but are 

not necessarily limited to: earplugs, teeth, bone, tympanic bullae, ear ossicles, baleen, eyes, muscle, 

skin, blubber, internal organs and tissues, reproductive organs, mammary glands, milk or colostrums, 

serum or plasma, urine, tears, blood or blood cells, cells for culture, bile, fetuses, internal and external 

parasites, stomach and/ or intestines and their contents, feces, air exhalate, flippers, fins, flukes, head 

and skull, and whole carcasses. Specimens may be acquired opportunistically with ongoing studies or 

prospective design plans; therefore specific numbers and kinds of specimens cannot be 

predetermined. Because all specimens will be acquired opportunistically, the MMHSRP will have 

minimal control over the age, size, sex, or reproductive condition of any animals that are sampled. 

During research activities, samples would not be collected from young of the year animals. Specific 

methods for biopsies, blood, breath, ultrasound, and other sampling are described below under the 

corresponding section. 

Marine mammal specimens collected for analysis or archiving would be legally obtained from the 

following sources: 

1. On-going live animal capture/release research programs authorized by this permit 

 or under separate permit of other researchers; 

2. Live animal capture/release as part of a stranding response, disease, emergency 

response, or die-off investigation of ESA-listed marine mammals in the U.S., and any 

marine mammal species abroad; 

3. Live ESA-listed animals stranded or in rehabilitation in the U.S. [and from any 

 marine mammal species abroad stranded or in rehabilitation]; 
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4. Captive animals (public display, research, or rehabilitating), when sampling is 

 beyond the scope of normal husbandry or normal rehabilitation practices (i.e., 

 intrusive research on ESA-listed or non-listed species); 

5. Captive public display or research animals during normal husbandry or other 

 permitted research; 

6. ESA-listed marine mammals found dead on the beach or at sea in the U.S.; and 

 any marine mammal species found dead on the beach or at sea in a foreign 

 country/waters. 

7. Animals directly taken in fisheries in countries where taking of such animals is legal; 

8. Animals killed during subsistence harvests by native communities; 

9. Animals killed incidental to recreational and commercial fishing operations; 

10. Animals killed incidental to other human activities; 

11. ESA-listed marine mammals found dead as part of NOAA investigations in the U.S. 

(e.g. harmful algal blooms, oil spills, etc.); 

12. Soft parts sloughed, excreted, or discharged by live animals (including blowhole 

exudate); 

13. Live animals during disease surveillance; 

14. Bones, teeth, or ivory of ESA-listed species found on the beach or on land within 

 1⁄4 mile of the ocean; 

15. Confiscated animals (e.g., as part of enforcement action); or 

16. Animals legally taken in other permitted research activities in the U.S. or abroad. 

Specimen and data collection from marine mammal carcasses may follow the necropsy protocols for 

pinnipeds (Dierauf 1994), right whales (and other large cetaceans) (McLellan et al. 2004), killer 

whales (Raverty and Gaydos 2004), small cetaceans (HSWRI 2005) and all marine mammals 

(Pugliares et al. 2007). These include how samples would be stored, transported, and analyzed. 

During live animal response or research, specimen and data collection protocols would depend on the 

samples being collected and the intended analyses. All sample analyses occur at various diagnostic 

laboratories in the U.S. and abroad. 
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1.1.11 Biopsy Sampling 

Biopsy sampling would be conducted to collect skin, blubber, muscle, or other tissue (see below for 

details) samples. Sampling may occur on free ranging animals and captured animals during research 

activities. Only skin and blubber biopsies would be collected remotely during research activities. 

Skin and blubber biopsy sampling from a vessel may be conducted using crossbows, compound 

crossbows, dart guns, or pole spears. The depth of the biopsy tip penetration would vary depending on 

the species being sampled, the need, and the depth of their blubber layer. For small cetaceans, such 

as bottlenose dolphins, the biopsy tip used to collect blubber for contaminant analysis penetrates to a 

depth of approximately 1.0-2.5 cm. Shorter tips may be used when only epidermal sampling is 

required. A crossbow would be used to collect a sample from animals within approximately 5 to 30 

m of the bow of the vessel. 

Remote biopsy darts may be used to collect skin and blubber biopsy samples from free-swimming 

cetaceans. This standard technique involves using a blank charge in a modified .22 caliber rifle to 

propel a dart with small cutting head 3-6 m into the side of a dolphin, below the dorsal fin. A stopper 

prevents the dart from penetrating to a depth greater than the thickness of the blubber and aids in the 

removal of the sample form the animal. The floating dart is retrieved, and the approximately 1 cm 

diameter by 1.5 – 2 cm long sample is processed for archiving and analysis. A video camera mounted 

on the sampling rifle allows evaluation of the response of the dolphin to the darting. 

Pole spears would be used to collect skin and blubber biopsy samples from small, bow-riding 

cetaceans. The biopsy tip is attached to the pole spear (approximately 5.5 m in length), which is 

tethered to a vessel. The pole spear is lowered to within 0.5 m of the target, which allows a specific 

area of the animal to be targeted with a high degree of accuracy. 

Blubber biopsies may be taken during health assessment studies. An elliptical wedge biopsy is 

obtained from each animal. For small cetaceans, the sampling site is located on the left side of the 

animal, just below the posterior insertion of the dorsal fin. Local anesthetic (typically Lidocaine) is 

injected in an L-block at the biopsy site. A veterinarian then uses a clean scalpel to obtain a sample 

that is approximately 5 cm long and 3 cm wide, through nearly the full depth of blubber 

(approximately 1.5-2.0 cm). A cotton plug soaked with ferric subsulfate is inserted into the site once 

the sample is removed in order to stop bleeding. The sample is then partitioned into separate 

containers for each project. Skin obtained with the blubber biopsy is used for genetic analyses. Skin 

scrapings, biopsy samples, or needle aspirates will be collected for clinical diagnoses from sites of 
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suspected lesion. These samples are processed by various diagnostic laboratories and a subsample is 

sent to the National Marine Mammal Tissue Bank. 

Biopsy sampling may also occur on animals in rehabilitation for diagnostic purposes. Skin and 

blubber may be collected as described above for capture animals. Biopsy sampling for diagnostic 

purposes would also include surgical procedures. Samples may be taken from muscle, lymph nodes, 

masses, abscesses, liver, kidneys, and other organs. Surgical procedures would be performed by 

experienced marine mammal veterinarians. 

Small muscle biopsies may be collected from pinnipeds. The procedure has been performed on a 

number of different pinniped species without adverse effects or complications (Kanatous et al. 1999; 

Ponganis et al. 1993). Prior to sampling, a local anesthetic will be injected subcutaneously and 

intramuscularly at the sampling site to minimize pain. The sampling site will be cleaned with a 

Betadine scrub and a small incision will be made with a scalpel blade. All biopsies will be taken 

using appropriately sized sterile biopsy punches at the incision. The punch will be pushed through 

the blubber and into the muscle layer and the biopsy (~50 mg) is then withdrawn and pressure is 

applied to the wound. The biopsy site will be irrigated with Betadine. Sutures are not needed for the 

wound. 

1.1.12 Blood Sampling 

Blood sampling in cetaceans may be collected from the dorsal fin, caudal peduncle, pectoral flipper, 

or flukes. Sampling at any of these sites would be done using an 18- gauge 4-cm needle, with a 

scaled down needle bore for calves, Dall’s porpoise, and harbor porpoise. Blood sampling of small 

cetaceans during health assessments may occur in the water prior to coming aboard the vessel, or 

once aboard the vessel. Typically, the blood sample is drawn from a blood vessel on the ventral side 

of the fluke, using an 18-20 gauge 3⁄4" catheter. Approximately 200-350 cubic centimeters (cc) of 

blood are removed from each individual. The samples are placed in a variety of Vacutainers and 

other containers specific to the analyses, and are stored in a cooler until they are transported to a 

laboratory. Some samples may be processed on deck with a portable centrifuge system. Samples are 

separated and prepared for: standard chemistry, hematology, and hormonal analysis; contaminant 

analyses; immune function studies; aliquots for culturing for assessment of pathogens; and other 

preparations as necessary. 

Blood samples in both phocids and otariids may be collected through the bilaterally divided 

extradural vein, which overlies the spinal cord. Otariids may also be sampled using the caudal gluteal 
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vein. Sampling would be done with a 20-gauge, 4-cm needle for small animals and an 18-gauge, 4-

cm needle for larger animals. Phocids may also be sampled by inserting a needle into the metatarsal 

region of the hind flipper (Geraci and Lounsbury 2005). 

1.1.13 Breath Sampling 

Breath sampling may be conducted on both ESA-listed and non-listed cetaceans to assess their 

nutritional status and health for research purposes only. Breath sampling will not be used as a 

diagnostic tool at this time. A specially designed vacuum cylinder would be used to collect breath 

samples. The system has previously been used on several cetacean species and elephants. Samples 

would be collected from free ranging cetaceans by positioning a funnel at the end of a pole (which is 

connected to the vacuum cylinder via plastic tubing) over the blowhole of the surfacing animal. The 

cylinder valve would be manually opened during exhalation. An algal culture plate inside the funnel 

would be used for bacterial cultures of the breath. The culture plate would be sealed and transported 

to a laboratory for analysis. The equipment typically would not touch the animal, although in some 

instances there may be brief (less than 10 seconds) contact. An individual animal may be approached 

up to three times to obtain a sample, if it is exhibiting avoidance behaviors. If an animal exhibits 

rapid evasion during approaches, the animal will not be pursued. Samples may also be collected 

during health assessments, emergency response activities, or on any live captured animal. Sampling is 

being conducted to determine if it may be an appropriate diagnostic tool. Samples will be taken from 

targeted populations at specific times to compare with visual assessments and/or biopsies. The 

samples will then be examined using gas chromatography-mass spectrometry for volatile compounds 

to evaluate respiratory disease, nutritional status, and physical condition. 

1.1.14 Ultrasound Sampling 

Ultrasound sampling may be conducted on all free ranging animals, animals captured during 

emergency response, or any species during research studies. Ultrasound may be used to evaluate 

blubber thickness, wounds, lesions, the presence of lesions, pregnancy, reproductive organs, and 

blood vessels. Ultrasound may also be used to evaluate cardiac function, other internal organs, and 

the presence of fat or gas emboli. B-mode, 2-D, and 3-D imaging may be used on marine mammals. 

Any standard diagnostic ultrasound unit with a “scroll” or “zoom” capability (to visualize deeper 

structures) would be used to examine marine mammals (Brook et al.2001). Transducer type will 

depend on the area of interest and the size of the patient. Chapter 26 of the CRC Handbook of Marine 

Mammal Medicine will be used as a reference for equipment and methods of ultrasonography for 

marine mammals (Brook et al. 2001). External and internal (transvaginal and transrectal) ultrasound 
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procedures may be conducted. During transvaginal and transrectal ultrasounds, a well lubricated 

transducer probe is inserted into the appropriate orifice to the minimum depth required to visualize 

the structures being observed. The length and diameter of the probe will be determined by the species 

and individual anatomy. Sedation may be necessary for the comfort of the animal. The level of 

sedation/restraint is at the discretion of the attending veterinarian. Cetacean ultrasounds will be 

conducted, as often as possible, while the animal is in water. 

For example, during health assessment studies of bottlenose dolphins, a diagnostic ultrasound is used 

to examine the condition of the internal organ and to measure testis length and diameter to assess 

male maturity. Females are also examined by a veterinarian during the initial evaluation for 

pregnancy and the presence of developing follicles. The ultrasound operates at a frequency of about 

2.5-5.0 MHz, well above the dolphin’s hearing. The examinations are recorded on video and audio 

tape, and thermal prints are made of features of interest. In addition, digital video thermography is 

used to measure skin temperature. 

1.1.15 Tooth Extraction 

The age determination of animals is conducted using the deposition of growth layer groups in teeth. 

A tooth is extracted from the animal by a veterinarian trained in this procedure. Tooth extraction 

typically occurs during cetacean health assessment studies. The tissue surrounding the tooth (usually 

#15 in the lower left jaw of cetaceans) is infiltrated with Lidocaine without epinephrine (or equivalent 

local anesthetic), applied through a standard, high-pressure, 30 gauge needle dental injection system. 

Once the area is anesthetized, the tooth is elevated and extracted using dental extraction tools. A 

cotton plug soaked in Betadine, or equivalent, solution is inserted into the alveolus (pit where the 

tooth was) as a local antibiotic and to stop bleeding. This plug is removed prior to release. This 

procedure is modified from that described by Ridgway et al. (1975), wherein the entire mandible was 

anesthetized. The revised procedure has been used in captivity and in live capture and release 

sampling for many years. Extracted teeth are sent to a laboratory for age determination. 

Tooth extraction in pinnipeds requires capture, restraint, and sedation. In pinnipeds, the post-canine 

or incisor teeth may be extracted. The tooth and gums are cleaned with an antiseptic solution before, 

during, and after the tooth is extracted. A scalpel is used to loosen attachments and the tooth is 

extracted with a dental elevator. Extraction methods would be similar to those described by Arnbom 

et al. (1992). 
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1.1.16 Urine Sampling 

Urine analyses are diagnostically useful to evaluate the urinary system (kidneys, ureters, bladder, and 

urethra). Important diagnoses can be made by determining the color, pH, turbidity, chemical 

constituents, presence or absence of blood, and by identifying any bacteria or yeast present in the 

urine. These diagnoses would likely be missed without such an examination. Samples may be 

collected using urinary catheterization. A veterinarian experienced with cetaceans or pinnipeds and a 

qualified veterinary technician would perform the catheterization procedure. For small cetaceans, the 

animal would be lying on its side on the foam-covered deck of the boat serving as the veterinary 

laboratory during health assessment studies. Wearing sterile surgical gloves, the assistant gently 

retracts the folds of the genital slit to allow visualization of the urethral orifice. The veterinarian 

(wearing sterile gloves) carefully inserts a sterile urinary catheter, lubricated with sterile lubricating 

gel, into the bladder via the urethra. A 50 ml collection tube without additive is used to aseptically 

collect the urine as it flows from the catheter. The catheter is removed after the urine is collected. 

Pinnipeds would be restrained and sedated before the catheter is inserted. The respiration, heart rate, 

and temperature of the animal would be monitored during the procedure. The animal would be 

monitored after the procedure until it is released. Urine may also be collected opportunistically, by 

holding an open sterile container in the urine stream. 

1.1.17 Blowhole Sampling 

Microbiological samples may be collected from the blowhole of a cetacean. A sterile swab is inserted 

into the blowhole during a breath, gently swabbed along the wall of the blowhole, and removed 

during the next breath. Samples are sent to a laboratory for culturing and species identification. 

1.1.18 Fecal Sampling 

Fecal samples are obtained either from a small catheter inserted about 10 cm into the colon or from a 

sterile swab of the rectum. The samples are sent to a diagnostic laboratory for culturing and species 

identification. Cetacean feces may also be collected in the water column either from a vessel or a 

diver in the water. Pinniped feces may be collected directly from haul-out or rookery sites. Samples 

are sent to a laboratory for culturing and species identification. 

1.1.19 Milk Sampling 

Milk samples are collected to measure the levels of lipophilic organic contaminants and to determine 

composition. All adult females are checked for lactation and milk samples are collected from all 
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lactating females. A “breast-pump” apparatus is used to obtain the sample. Milk is expressed with 

gentle manual pressure exerted on the mammary gland while suction is provided by a 60 cc syringe 

attached by tubing to another 12 cc syringe placed over the nipple. Samples of up to 30-50 ml may be 

collected. 

1.1.20 Sperm Sampling 

A potential impact of environmental contaminants on animal health is the reduction of reproductive 

capabilities. This may be measured indirectly in males through ultrasonic examination, measurement 

of testes, and measurement of testosterone concentrations. Collection and examination of sperm 

samples would be a more direct measurement of male reproductive function. If possible, ejaculate 

samples would be collected through manual manipulation of the penis. Samples are examined for 

sperm count, motility, and condition. 

1.1.21 Colonic Temperature 

Colonic temperature is collected to understand vascular cooling and reproductive status (Rommel et 

al.1992, 1994). Temperature measurements are obtained with a linear array of thermal probes 

interfaced to a laptop computer. The probes are typically housed in a 3 mm OD flexible plastic tube. 

The probe is sterilized, lubricated, and then inserted into the colon through the anus to a depth of 

0.25-0.40 m, depending on the size of the animal. Temperature is continuously monitored. 

1.1.22 Gastric Sampling 

Gastric samples may be obtained using a standard stomach tube to evaluate health and evidence of 

toxin exposure. 

1.1.23 Hair, Nails, and Vibrissae Sampling 

A vibrissa may be pulled from anesthetized pinnipeds (age limit greater than 2 months). Vibrissae are 

pulled by gripping with forceps or fingers and pulling forcefully and rapidly in one smooth motion. 

Nails will be also be clipped close to the base of the nail bed without causing bleeding. Hair samples 

will be collected with scissors at the base of the hair without removing the follicle. 

1.1.24 Administration of Drugs and Euthanasia 

Drugs may be administered for sedation/chemical restraint during stranding response and 

disentanglement activities. These procedures would be performed or directly supervised by qualified 
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personnel and, if possible, an experienced marine mammal veterinarian would be present to carry out 

or provide direct on-site supervision of all activities involving the use of anesthesia and sedatives. 

Anesthetics and analgesics may be used during research before performing biopsies, tooth 

extractions, and other procedures. Antibiotics, antifungals, and other medicines may be administered 

during response and rehabilitation of ESA-listed species. Chapter 31 of the CRC Handbook of 

Marine Mammal Medicine will be used as a reference for potential drugs and doses for marine 

mammal species (Stoskopf et al. 2001). Drugs may be administered orally or through injection, 

intubation, or inhalation. Orally administered medications are typically hidden in fish but may also 

be given via stomach tube. 

Subcutaneous (SQ), IV, IM, intraperitoneal (IP), and intranasal injections may be used to deliver 

drugs. All of these methods would require some level of animal restraint. SQ injections are made in 

the interface between the blubber layer and the skeletal muscle layer. Animals must be maintained in 

a certain position for prolonged periods of time. The most common site for SQ injections in 

pinnipeds is the craniodorsal thorax between the scapulae. SQ injections would not be used in 

cetaceans. 

In general, IV injections are complicated and rarely used in marine mammals. In cetaceans, 

medications may be injected in the fluke vessel if the volume is low and the medicine is not harmful 

if delivered perivascularly. An indwelling catheter may be used if repeated administration or slow 

infusion occurs (McBain 2001). 

IM drug injections require longer needles because of the thickness of skin and blubber. Caution is 

taken to avoid accidental injection into the blubber, which may cause sterile abscess formation or 

poor absorption (Gulland et al. 2001). Injection into the blubber also has different drug-partitioning 

properties than muscle. This may result in the failure to activate a systemic distribution of highly 

lipid soluble medications (Stoskopf et al. 2001). Injection sites for phocids are the muscles 

surrounding the pelvis, femur, and tibia. These sites, as well as the large muscles overlying the 

scapulae, are appropriate for otariids (Gulland et al. 2001). IM injections in cetaceans may be made 

off the midline, slightly anterior to, parallel to, or just posterior to the dorsal fin. Caution is taken to 

avoid the thoracic cavity if the injection is anterior to the dorsal fin (McBain 2001). Multiple 

injection sites may be used and the volume per site should be reasonable depending on the animal. 

IP injections deliver medications into the abdominal cavity. Non-irritating drugs may be delivered by 

this method. During injection, caution must be taken to avoid damaging major organs. A 
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contaminated needle or puncturing the gastrointestinal tract could introduce bacteria into the 

abdominal cavity (Gulland et al. 2001). Intranasal methods may be used to deliver drugs to 

cetaceans, via the blowhole (Dunn 2006). 

Euthanasia of an ESA-listed animal may be conducted if: an animal had an irreversibly poor 

condition and rehabilitation would not be possible; rescue would be impossible; or no rehabilitation 

facility is available. Euthanasia may occur at a rehabilitation facility when an animal is deemed 

unreleasable and cannot be placed in permanent captivity. Humane euthanasia procedures would 

only be carried out by an attending, experienced, and licensed veterinarian or other qualified 

individual. Sedation may precede the administration of euthanasia drugs. Pinnipeds are typically 

euthanized using a lethal injection of barbiturates or other agent normally used to euthanize domestic 

species. Smaller cetaceans can be euthanized by injecting barbiturates or other lethal agent into a 

vein of the flippers, dorsal fin, flukes, or caudal peduncle. It may also be injected directly into the 

heart of abdominal cavity using an in-dwelling catheter. A small cetacean may be sedated before 

injection occurred. For large cetaceans, a method is currently being developed to sedate the animal 

via IM injection and then deliver euthanasia agents via IV. Large cetaceans may be euthanized by 

lethal injection directly into the heart. Injection into a vein of the flippers or flukes would likely be 

unsuccessful. Large whales may also be euthanized via intranasal method (injection into the 

blowhole) (Dunn 2006). Large whales may be euthanized by using ballistics (shooting) or by 

exsanguination (Geraci and Lounsbury 2005) 

1.1.25 Auditory Brainstem Response /Auditory Evoked Potential 

Auditory Brainstem Response (ABR) and Auditory Evoked Potential (AEP) procedures may be 

conducted as a method to evaluate the hearing abilities of individual animals or species. Procedures 

may be conducted on stranded animals, animals in rehabilitation, or on animals captured during 

research studies. The ABR technique involves repeatedly playing a test sound stimulus while 

simultaneously recording the neural evoked potential from surface electrodes. 

1.1.25.1 Pinniped Testing Procedures 

Pinniped audiometric testing may be conducted while individuals undergo scheduled sedation and/or 

anesthesia for necessary medical procedures during rehabilitation. SQ electrodes are used for 

obtaining electrophysiological recordings from pinnipeds and are harmless to the animals. The SQ 

electrodes are sterile 27 gauge x 10 mm needles that are place subcutaneously beneath the skin on the 

animals’ head. One or two electrodes record AEPs and the other is a reference or ground electrode, 
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which subtracts the biological noise produced by the animal to enhance the recorded evoked potential 

responses. 

Testing would be conducted under the supervision of the rehabilitation facility’s attending 

veterinarian. Individuals are not tested more than once and testing sessions do not last longer than 60 

minutes, except in cases where the individual requires euthanasia upon completion of the anesthetic 

procedure. Testing time has no impact on animal health or recovery from anesthesia in these 

individuals. Therefore, in situations where animals require euthanasia upon completion of anesthesia, 

testing may be allowed to continue for longer intervals at the discretion of the attending veterinarian. 

This protocol maximizes the amount of information that can be obtained from each subject, improves 

the quality of the data, and precludes any potential residual impact on anesthetic recovery on the 

individuals tested. Cases in which animals require euthanasia following anesthesia will be given 

highest priority in screening for potential study candidates. 

1.1.25.2 Odontocete Testing Procedures 

Procedures on odontocetes are non-invasive and can be conducted in short time frames. An animal 

may be resting at the surface or may be physically restrained (held by researchers) during the 

procedure. ABR signals are collected through suction cup electrodes. Standard EEG gel is used on 

the electrodes to establish an electrical connection between the electrode and the skin. Sounds may be 

presented through a jawphone attached to the lower jaw via suction cup. Sounds may also be 

presented in the water and the animals hear naturally through their lower jaws and other sound paths 

to the ear. A reference electrode is attached near the dorsal fin and a recording electrode is attached 

about 5 cm behind the blowhole. The electrodes are on the surface of the skin and are connected to 

an amplifier via long wires that exceed the length of the tank. The suction cups can easily be 

removed if there is any difficulty with the procedure. Evoked potentials are recorded from the 

electrodes. Frequencies used for testing range from 1 to 160 kHz (the range of frequencies that many 

odontocetes hear) and the maximum sound pressure level is less than 160 decibels re μPa. 

Procedures would only be conducted on odontocetes. AEP procedures would not be conducted on 

mysticetes as there is no documentation on methodology that is likely to be successful in applying 

audiometric procedures on mysticetes. AEP experiments with animals of this size are inherently 

difficult for a number of reasons and mysticete anatomy presents additional challenges. All AEP 

procedures performed on stranded and rehabilitating odontocetes and pinnipeds will follow NMFS 

PR1 policies and protocols. Testing would not delay treatment, movement, or release of a stranded 
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animal nor would it interfere with rehabilitation activities. Testing would be stopped if an animal 

exhibited any adverse reaction, including abnormal respiration and locomotion, vocalization, 

vomiting, or other signs of distress. 

1.1.26 Import and Export of Marine Mammals or Marine Mammal Parts 

Exportation privileges are necessary for the MMHSRP to provide specimens to the international 

scientific community for analyses or as control/standard reference materials and to export animals for 

release. Importation privileges are necessary for the MMHSRP to acquire legally obtained specimens 

from outside the U.S. for archival in the National Marine Mammal Tissue Bank or for real time 

analyses. Importation privileges are also necessary to import live animals for treatment. An unlimited 

number and kinds of marine mammal specimens, including cell lines, would be imported or exported 

(worldwide) at any time during the year. Imported and exported specimens would include those 

taken from the Order Cetacea, Order Pinnipedia (including walrus), Order Sirenia, polar bear, sea 

otter, and marine otter; this includes threatened and endangered species. Specimen materials may 

include, but are not necessarily limited to: earplugs, teeth, bone, tympanic bullae, ear ossicles, baleen, 

eyes, muscle, skin, blubber, internal organs and tissues, reproductive organs, mammary glands, milk 

or colostrums, serum or plasma, urine, tears, blood or blood cells, cells for culture, bile, fetuses, 

internal and external parasites, stomach/intestines and their contents, feces, flippers, fins, flukes, head 

and skull, and whole carcasses. Specimens would be acquired opportunistically; therefore specific 

numbers and kinds of specimens, the countries of exportation, and the countries of origin cannot be 

predetermined. 

Most specimens would be acquired opportunistically, and the MMHSRP will have minimal control 

over the age, size, sex, or reproductive condition of any animals that are sampled. However, in cases 

of prospective or retrospective analyses for a given health related study, these conditions would be 

provided to NMFS PR1 before activities occur. Imported specimens would be legally obtained from: 

• Animals directly taken in fisheries for such animals in countries and situations where 

such taking is legal and humane; 

• Animals killed during subsistence harvest by native communities; 

• Animals killed incidental to commercial fishing operations; 

• Animals stranded live; 

• Animals found dead on the beach or at sea; 
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• Captive animals, when sampling is beyond the scope of normal husbandry practices 

or when sampling is taken during normal husbandry practices; and 

• Live animals in a permitted, live capture study. 

An unlimited number and kinds of marine mammal specimens, including cell lines, would be 

imported and/or exported (worldwide) at any time during the year. Specimens would be taken from 

the Order Cetacea and the Order Pinnipedia (except walrus), including threatened and endangered 

species. Specimen materials may include, but are not limited to: earplugs; teeth; bone; tympanic 

bullae; ear ossicles; baleen; eyes; muscle; skin; blubber; internal organs and tissues; reproductive 

organs; mammary glands; milk or colostrums; serum or plasma; urine; tears; blood or blood cells; 

cells for culture; bile; fetuses; internal and external parasites; stomach and/or intestines and their 

contents; feces; flippers; fins; flukes; head and skull; and whole carcasses. Specimens are acquired 

opportunistically; therefore specific numbers and kinds of specimens, the countries of exportation, 

and the countries of origin cannot be predetermined. 

All marine mammals under NMFS jurisdiction, including ESA-listed species, may be imported or 

exported for medical treatment. Transport methods would be the same as those described in Section 

1.1.5. 
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2. New ESA/MMPA Permit Activities 

This Section describes scientific research and enhancement activities that may potentially be 

conducted under the new ESA/MMPA permit. 

2.1.1 Blood Sampling 

Currently, no procedures exist to remotely collect blood from free-swimming animals. However, if 

blood sampling procedures are developed and approved within the timeframe of the permit (five 

years), the MMHSRP would use these to conduct research. All protocols (including species) would 

be provided to NMFS PR1 for approval prior to any research activity. 

2.1.2 Health Assessment Studies 

In addition to the current health assessment studies on bottlenose dolphins, future studies would be 

conducted on other cetacean species. New tagging, tracking, and telemetry packages would also be 

used. All species and methods would be provided to NMFS PR1 for approval before any activities 

occurred. 

2.1.3 Acoustics 

The use of AEP procedures on any mysticete would not occur under the current ESA/MMPA permit. 

However, if a successful methodology for applying audiometric procedures on mysticetes is 

developed within the timeframe of the permit (five years), the MMHSRP would likely use these to 

conduct research. All protocols (including species) would be provided to NMFS PR1 for approval 

prior to any research activity. 

Passive acoustic recording would involve the used of a hydrophone (underwater microphone). A 

hydrophone would be placed in the water directly off of a vessel or in a pool, and sounds would be 

recorded and taped via an apparatus on the vessel or on the pool deck. The purpose of passive 

acoustic recording is to record the vocalizations of a group of animals and/or the background noise in 

an area around the group of animals. Passive acoustic recording also indirectly provides background 

information on noise and vocalizations. 

Active acoustic playbacks would be used to expose cetaceans and pinnipeds to playbacks of prerecorded songs, social sounds, and feeding calls of that species. Playbacks may be used during 

capture and release activities and during rehabilitation. Sounds and songs would be projected from an 

underwater speaker hung over the side of a small vessel or in a pool. Sounds or songs would be 
H-27

projected from the speaker at a volume and quality as close to a real sound/song as possible. The 

playback system would be calibrated so precise levels of sound can be projected. The physiological 

and/or physical response of the animals to the sounds and songs would be measured, often through 

behavioral observation and photographs/video recording of the subject animal(s). Playbacks would 

be used to determine if an animal can hear and assess how they are responding to sounds. This 

information would be used to determine the releasability of a rehabilitated animal. 

2.1.4 Cognitive Assessment of Sea Lions in Rehabilitation Suffering 

from Domoic Acid Intoxication. 

This study is designed to increase the extent of clinical assessment of California sea lions exposed to 

domoic acid. Standard veterinary clinical procedures have been used to evaluate the health and 

prognosis for survival of these cases, including hematology, serum biochemistry, MRI, EEG, and 

satellite tagging to monitor released animals. Work to date on sea lions (Goldstein et al. 2008) and 

parallel studies in laboratory animals suggest that there may be additional impacts on sea lion health 

due to changes in behavior and cognitive function. In an effort to qualify and quantify the cognitive 

effects of domoic acid exposure on California sea lions, subjects will be assessed will in rehabilitation 

using behavioral methods. Performance will be evaluated on simple tasks designed to reveal aspects 

of cognitive function, including auditory habituation, behavioral flexibility, spatial memory, and 

object recognition. Both passive (observational) and active (food reward) approaches will be used. 

Direct human contact will be minimized and should not exceed that typically experienced in a 

rehabilitation setting. 

The California sea lion subjects to be assessed will be selected by the veterinary staff at The Marine 

Mammal Center (TMMC) (Sausalito, CA) from the pool of animals undergoing rehabilitation. 

Subjects will include prescreened animals identified as domoic acid exposed (by fecal samples, EEG, 

MRI, and basic neurological assessment) and an equal number of prescreened controls with no 

apparent neurological deficits (e.g., trauma and malnutrition cases). A maximum of 50 exposed sea 

lions and 50 controls will be evaluated, but the actual number of subjects will depend on animal 

availability during the course of the study. Animals of all ages will be examined, based on the 

availability of stranded animals. Assays will be conducted at TMMC or at the Long Marine 

Laboratory’s (Santa Cruz, CA) marine mammal holding facilities. Each subject will be evaluated 

during a period not to exceed 30 days. Medical care, feeding schedules, and activity levels for 

subjects will be similar to those provided for animals in standard rehabilitation settings. Upon 

completion of their participation, subjects will be assessed for release, continued care, or euthanasia 
H-28

by the TMMC veterinary staff according to their standard operating procedures. Decisions on the 

disposition of each animal will be based on medical condition and the ability to survive in the wild, 

according to the NMFS release guidelines for marine mammals in rehabilitation. 
H-29

3. References 

Arnbom et al. 

1992 

Arnbom, T.A., N.J. Lunn, I.L. Boyd, and T. Barton. 1992. Aging Live Antarctic Fur 

Seals and Southern Elephant Seals. Marine Mammal Science 8(1): 37-43. 

Dierauf 1994 Dierauf, L.A. 1994. Pinniped forensic, necropsy and tissue collection guide. NOAA 

Technical Memorandum NMFS-OPR-94-3. U.S. Department of Commerce, National 

Oceanic and Atmospheric Administration, National Marine Fisheries Service, Silver 

Spring, MD. 

Dunn 2006 Dunn, J.L. 2006. Multiple-agent euthanasia of a juvenile fin whale, Balaenoptera 

physalus. Marine Mammal Science 22(4): 1004-1007. 

Galimberti et 

al. 2000 

Galimberti, F. and S. Sanvito. 2000. Marking of southern elephant seals with passive 

integrated transponders. Marine Mammal Science 16(2): 500-504. 

Geraci and 

Lounsbury 

2005 

Geraci, J.R. and V.J. Lounsbury. 2005. Marine Mammals Ashore: A Field Guide for 

Strandings, Second Edition. National Aquarium in Baltimore, Baltimore, MD. 

Gulland et al.

2001 

Gulland, F.M.D., M. Haulena, and L.E. Dierauf. Seals and Sea Lions. In: CRC Handbook 

of Marine Mammal Medicine. Second Edition. L.A. Dierauf and F.M.D. Gulland, eds. 

CRC Press LLC, Boca Raton, FL. 

HSWRI 2006 Hubbs-SeaWorld Research Institute (HSWRI). 2006. Workshop to Evaluate the Potential 

for Use of Morbillivirus Vaccination in Hawaiian Monk Seals. Final Report. San Diego, 

CA. 

IATA 2006 International Air Transport Association (IATA). 2006. Live Animal Regulations. 33rd

Edition. International Air Transport Association, Montreal, Quebec, Canada. 

Jeffries et al. 

1993 

Jeffries, S.J., R.F. Brown, and J.T. Harvey. 1993. Techniques for capturing, handling and 

marking harbour seals. Aquatic Mammals 19.1: 21-25. 

Kanatous et 

al. 1999 

Kanatous, S. B., L. V. DiMichele, D. F. Cowan, and R. W. Davis. 1999. High aerobic 

capacities in the skeletal muscles of pinnipeds: adaptations to diving hypoxia. Journal of 

Applied Physiology 86:1247-1256. 

Litzky et al. 

2001 

Litzky, L.K., R.C. Hobbs, and B.A. Mahoney. 2001. Field report for tagging study of 

beluga whales in Cook Inlet, Alaska, September 2000. In: Marine Mammal Protection 

Act and Endangered Species Act Implementation Program 2000. Alaska Fisheries 

Science Center Processed Report 2001-06. A.L. Lopez and R.P. Angliss, eds. U.S. 

Department of Commerce, National Oceanic and Atmospheric Administration, National 

Marine Fisheries Service, Alaska Fisheries Science Center, Seattle, WA. 

McBain 2001 McBain, J.F. 2001. Cetacean Medicine. In: CRC Handbook of Marine Mammal 

Medicine. Second Edition. L.A. Dierauf and F.M.D. Gulland, eds. CRC Press LLC, Boca 

Raton, FL. 

McLellan et 

al. 2004 

McLellan, W.A, S.A. Rommel, M. Moore, and D. A. Pabst. 2004. Right whale necropsy 

protocol. Final Report to NMFS for Contract No. 40AANF112525. 

 
H-30

Merrick et al.

1996 

Merrick, R.L., T.R. Loughlin, and D.G. Calkins. 1996. Hot-Branding: A Technique for 

Long-term Marking of Pinnipeds. NOAA Technical Memorandum NMFS-AFSC-68. U.S. 

Department of Commerce, National Oceanic and Atmospheric Administration, National 

Marine Fisheries Service, Alaska Fisheries Science Center, Seattle, WA. 

Petras 2003 Petras, E. 2003. A Review of Marine Mammal Deterrents and Their Possible Applications 

to Limit Killer Whale (Orcinus orca) Predation on Steller Sea Lions (Eumetopias 

jubatus). AFSC Processed Report 2003-02. National Ocean and Atmospheric 

Administration, National Marine Fisheries Service, Seattle, WA. 

Pugliares et al. 

2007 

Pugliares, K.R., A. Bogomolni, K.M. Touhey, S.M. Herzig, C.T. Harry, and M.J. Moore. 

2007. Marine Mammal Necropsy: An Introductory Guide for Stranding Responders and 

Field Biologists. Woods Hole Oceanographic Institution Technical Report WHOI-2007- 

06. Woods Hole, MA. 

Raverty and 

Gaydos 2004 

Raverty, S.A. and J.K. Gaydos. 2004. Killer whale necropsy and disease testing protocol. 

SeaDoc Society, Wildlife Health Center, University of California Davis, School of 

Veterinary Medicine. 

Reeves et al.

1996 

Reeves, R.R., R.J. Hofman, G.K. Silber, and D. Wilkinson. 1996. Acoustic Deterrence of 

Harmful Marine Mammal-Fisheries Interactions: Proceedings of a Workshop Held in 

Seattle, Washington, 20-22 March 1996. NOAA Technical Memorandum NMFS-OPR10. U.S. Department of Commerce, National Oceanic and Atmospheric Administration, 

National Marine Fisheries Service, Silver Spring, MD. 

Ridgway et al. 

1975

Ridgway, S.H., R.F. Green, and J.C. Sweeney. 1975. Mandibular anesthesia and tooth 

extraction in the bottlenose dolphin. Journal of Wildlife Diseases 11:415-428. 

Rommel et al. 

1992 

Rommel, S.A., D.A. Pabst, W.A. McLellan, J.G. Mead, and C.W. Potter. 1992. 

Anatomical evidence for countercurrent heat exchanger associated with dolphin testes. 

The Anatomical Record 232 (1):150-156. 

Rommel et al.

1994 

Rommel, S.A., D.A. Pabst, W.A. McLellan, T.M. Williams, and W.A. Friedl. 1994. 

Temperature regulation of the dolphin testes: evidence from colonic temperatures. 

Journal of Comparative Physiology B: Biochemical, Systemic, and Environmental 

Physiology 164: 130-134. 

Stoskopf et al.

2001 

Stoskopf, M.K., S. Willens, and J.F. McBain. 2001. Pharmaceutical and Formularies. In: 

CRC Handbook of Marine Mammal Medicine. Second Edition. L.A. Dierauf and F.M.D. 

Gulland, eds. CRC Press LLC, Boca Raton, FL. 

Thomas et al. 

1987 

Thomas, J.A., L.H. Cornell, B.E. Joseph, T.D. Williams, and S. Dreischman. 1987. An 

implanted transponder chip used as a tag for sea otters (Enhydra lutris). Marine Mammal 

Science 3(3): 271-274. 

USN 2004 U.S. Navy (USN), Pacific Fleet. 2004. Report on the results of the inquiry into 

allegations of marine mammal impacts surrounding the use of active sonar by USS Shoup

(DDG 86) in the Haro Strait on or about 5 May 2003. 

Wright et al. 

1998 

Wright, I.E., S.D. Wright, and J.M. Sweat. 1997. Use of passive integrated transponder 

(PIT) tags to identify manatees (Trichechus manatus latirostris). Marine Mammal 

Science: 14(3): 641-645. 
H-31 

4. Acronyms 

ABR Auditory Brainstem Response 

AEP Auditory Evoked Potential 

APHIS Animal and Plant Health 

Inspection Service 

cc Cubic centimeter 

ESA Endangered Species Act 

HSWRI Hubbs-SeaWorld Research 

Institute 

IATA International Air Transport 

Association 

IM Intramuscular 

IP Intraperitoneal 

IV Intravenous 

LHX Life History transmitter 

m Meter 

MMHSRP Marine Mammal Health and 

Stranding Response Program 

MMPA Marine Mammal Protection Act 

NMFS PR1 

National Marine Fisheries 

Service, Office of Protected 

Resources, Permits, 

Conservation and Education 

Division 

NMMTB National Marine Mammal Tissue 

Bank 

NOAA National Oceanic and 

Atmospheric Administration 

PIT Passive Integrated Transponder 

SQ Subcutaneous 

TDR Time-depth Recorder 

UME Unusual Mortality Event 

VHF Very High Frequency 
THIS PAGE INTENTIONALLY LEFT BLANK 
APPENDIX I 

REQUIRED TAKE TABLES FOR THE ESA/MMPA PERMIT 

APPLICATION

Table 1. Activities representatives of the National Marine Fisheries Service’s Marine Mammal Health and Stranding Response Program 

conduct under the proposed permit Species Life Stage Gender 

Expected 

Number of 

Individuals 

"Taken1" 

Number of 

Times an 

Individual Might 

be "Taken" 

Proposed Action Transport Lo

Project 1: Emergency Response Activities All ESA-listed Cetacea, all ESA-listed Pinnipedia under NMFS jurisdiction 

All (no 

restriction on 

age class) 

M/F 

As warranted to 

respond to 

emergencies* 

As warranted to 

respond to 

emergencies2

Close approach, aerial and vessel surveys, disentanglement, capture, restraint, handling, tagging, marking (excluding hot branding), sample collection (including biopsy), sample analysis, anesthesia, sedation, treatment, import/export of animals, transport, relocation, rehabilitation, release, hazing away from harmful situations; and acoustic sampling, recording, and playbacks 

Live animals may be transported to rehabilitation facilities and release sites. Live animals may be relocated 

Beachwaters US, wawithin EEZ, ainternawaters exportimportanimawide 

All ESA-listed Cetacea, all ESA-listed Pinnipedia under NMFS jurisdiction 

All M/F 

As warranted to 

respond to 

emergencies* 

As warranted to 

respond to 

emergencies* 

Euthanasia, necropsy, carcass disposal 

Carcasses may be transported to disposal sites or laboratories 

Beachwaters US, anwithin EEZ 

All ESA-listed Cetacea, all ESA-listed Pinnipedia under NMFS jurisdiction 

All M/F 

As warranted to 

respond to 

emergencies* 

As warranted to 

respond to 

emergencies* 

Accidental mortality, necropsy, carcass disposal 

Carcasses may be transported to disposal sites or laboratories 

Beachwaters US, anwithin EEZ 

All Cetacea, all Pinnipedia (including walrus), sea otter, manatee, and polar bear3

All M/F 

As warranted to 

respond to 

emergencies* 

As warranted to 

respond to 

emergencies* 

Incidental harassment N/A 

Beachwaters US, anwithin EEZ 
Table 1. Activities representatives of the National Marine Fisheries Service’s Marine Mammal Health and Stranding Response Program 

conduct under the proposed permit Species Life Stage Gender 

Expected 

Number of 

Individuals 

"Taken1" 

Number of 

Times an 

Individual Might 

be "Taken" 

Proposed Action Transport Lo

All Cetacea, all Pinnipedia (including walrus), sea otter, manatee, dugong, and polar bear3

All M/F 

As warranted to 

respond to 

emergencies* 

As warranted to 

respond to 

emergencies* 

Receipt, import/export of samples 

Analytical and diagnostic samples may be transported, imported or exported as needed to laboratories 

Beachwaters US, wawithin EEZ, ainternawaterswide im/expor

Project 2: Prospective Health Assessment Research Activities Pinnipedia (except Guadalupe fur seal, Hawaiian monk seal, and Steller sea lion) 

All M/F Unlimited 5 Close approach, aerial and vessel surveys None 

Coastaof the EEZ, internawaters 

Pinnipedia (except Guadalupe fur seal, Hawaiian monk seal, and Steller sea lion) 

All M/F Up to 300 annually (total) 5 

Capture (net or hand), restraint, handling, tagging, marking (excluding hot branding), sample collection (including biopsy), release; and acoustic sampling, recording, and playbacks 

None 

Coastaof the EEZ, internawaters 

Pinnipedia (except Guadalupe fur seal, Hawaiian monk seal, and Steller sea lion) 

All M/F 3 annually (total) 1 Accidental mortality during capture activities None 

Coastaof the EEZ, internawaters 

Pinnipedia (except Guadalupe fur seal, Hawaiian monk, seal and Steller sea lion) 

All M/F Up to 400 annually (total) 5 

Collection of samples during other legal takes/permitted activities (subsistence harvest, by-catch, live capture/release) 

None 

Coastaof the EEZ, internawaters 

ESA-listed Hawaiian monk seals and Guadalupe fur seals that are held in captivity and are not releasable back into the wild; and those undergoing rehabilitation 

All M//F 

As warranted to 

satisfy the 

requirements of 

study design 

As warranted to 

satisfy the 

requirements of 

study design 

Capture (net or hand), restraint, handling, tagging, marking (excluding hot branding), sample collection (including biopsy), release; and acoustic sampling, recording, and playbacks 

None 

Captivfacilitieincludirehabicenter
Table 1. Activities representatives of the National Marine Fisheries Service’s Marine Mammal Health and Stranding Response Program 

conduct under the proposed permit Species Life Stage Gender 

Expected 

Number of 

Individuals 

"Taken1" 

Number of 

Times an 

Individual Might 

be "Taken" 

Proposed Action Transport Lo

Small Cetacea (Tursiops, Stenella, Steno, Delphinus, Lagenorhynchus Lagenodelphis, Lissodelphis, Grampus, Peponocephala, Feresa, Pseudorca, Orcinus, Globicephala, Phocoena, Phocoenoides, Kogia, Delphinaterus, all beaked whales) 

All M/F Unlimited 5 Close approach, aerial and vessel surveys None 

Coastaof the EEZ, internawaters 

Small Cetacea (see above) All except YOY M/F Up to 200 annually (total) 5 

Capture (net or hand), restraint, handling, tagging, marking (including freeze branding), sample collection, release; and acoustic sampling, recording, and playbacks 

None 

Coastaof the EEZ, internawaters 

Small Cetacea (see above) All except YOY M/F 3 annually (total) 1 Accidental mortality during capture activities None 

Coastaof the EEZ, internawaters 

Small Cetacea (see above) All except YOY M/F Up to 400 annually (total) 5 

Collection of samples during other legal takes/permitted activities (subsistence harvest, by-catch, live capture/release) 

None 

Coastaof the EEZ, internawaters 

Large Whales (gray, right, humpback, fin, blue, sei, Bryde’s, minke, bowhead, and sperm whales) 

All except 

calves ≤ 6 

months in age and cows with 

calves 

M/F Up to 5,000 annually (total) 5 Close approach, aerial and vessel surveys None 

Coastaof the EEZ, internawaters 

Large Whales (same species as the previous entry) 

All except 

calves ≤ 6 

months in age and cows with 

calves (for 

M/F Up to 100 annually (total) 5 

Tagging and sample collection (including biopsy and respiratory gases), acoustic sampling (including recording and playback 

None 

Coastaof the EEZ, internawaters 
Table 1. Activities representatives of the National Marine Fisheries Service’s Marine Mammal Health and Stranding Response Program 

conduct under the proposed permit Species Life Stage Gender 

Expected 

Number of 

Individuals 

"Taken1" 

Number of 

Times an 

Individual Might 

be "Taken" 

Proposed Action Transport Lo

tagging and 

sampling) 

experiments), collection of feces, photo-identification (for visual health assessment and ID) 

Large Whales (same species as the previous entry) 

All M/F Up to 400 annually (total) 5 

Collection of samples during other lawful “takes”/permitted activities (subsistence harvest, by-catch, live takes) 

None 

Coastaof the EEZ, internawaters 

All Cetacea, all Pinnipedia (including walrus), marine and sea otter, manatee, dugong, and polar bear 

All M/F 

As warranted to 

satisfy the 

requirements of 

study design 

As warranted to 

satisfy the 

requirements of 

study design 

Receipt, import/export of samples 

Analytical and 

diagnostic 

samples may be 

transported, 

imported or 

exported as 

needed to 

laboratories 

Beachwaters US, wawithin EEZ, ainternawaterswide im/expor

Project 3: Cognitive Assessment of Sea Lions in Rehabilitation with Domoic Acid Intoxication Zalophus californianus All M/F 

Up to 50 domoic 

acid exposed 

animals and up 

to 50 controls 

(total) 

30 (up to 1/day) Restraint, handling, and sample collection 

Animals may be transported to Long Marine Laboratory. 

AnimarehabiThe MMamm

Zalophus californianus All M/F 

Up to 50 domoic 

acid exposed 

animals (total) 

1 Accidental mortality during research activities None 

AnimarehabiThe MMamm

1 The ESA defines “take” as “harass, harm, pursue, hunt, shoot, would, kill, trap, capture, or collect, or attempt to engage in any such conduct” (16 U.S.C. 1532). 

2. Due to the nature of stranding and entanglement events, the specific numbers of individuals that might be “taken” during responses to these events cannot be d

3. dugongs, manatees, polar bears, sea otters, and walruses are under the jurisdiction of the U.S. Fish and Wildlife Service and are not addressed in this biologica
Table 2. Activities representatives of the National Marine Fisheries Service’s Marine Mammal Health and Stranding Response Program 

conduct on endangered or threatened species under the proposed permit Species Life Stage Gender 

Expected Number 

of Individuals 

"Taken1" 

Number of 

Times an 

Individual Might 

be "Taken" 

Proposed Action Transport 

Project 1: Emergency Response Activities All ESA-listed Cetacea, all ESA-listed Pinnipedia under NMFS jurisdiction 

All (no 

restriction 

on age 

class) 

M/F 

As warranted to 

respond to 

emergencies2

As warranted to 

respond to 

emergencies* 

Close approach, aerial and vessel surveys, disentanglement, capture, restraint, handling, tagging, marking (excluding hot branding), sample collection (including biopsy), sample analysis, anesthesia, sedation, treatment, import/export of animals, transport, relocation, rehabilitation, release; hazing away from harmful situations; and acoustic sampling, recording, and playbacks 

Live animals may be transported to rehabilitation facilities and release sites. Live animals may be relocated 

Bewathe its posadjwaimpani

All ESA-listed Cetacea, all ESA-listed Pinnipedia under NMFS jurisdiction 

All M/F 

As warranted to 

respond to 

emergencies* 

As warranted to 

respond to 

emergencies* 

Euthanasia, necropsy, carcass disposal 

Carcasses may be transported to disposal sites or laboratories 

Bewathe its posadjwa

All ESA-listed Cetacea, all ESA-listed Pinnipedia under NMFS jurisdiction 

All M/F 

As warranted to 

respond to 

emergencies* 

As warranted to 

respond to 

emergencies* 

Accidental mortality, necropsy, carcass disposal 

Carcasses may be transported to disposal sites or laboratories 

Bewathe its posadjwa

All Cetacea, all Pinnipedia (including walrus), sea otter, manatee, and polar bear3

All M/F 

As warranted to 

respond to 

emergencies* 

As warranted to 

respond to 

emergencies* 

Incidental harassment N/A 

Bewathe its posadjwa
Table 2. Activities representatives of the National Marine Fisheries Service’s Marine Mammal Health and Stranding Response Program 

conduct on endangered or threatened species under the proposed permit Species Life Stage Gender 

Expected Number 

of Individuals 

"Taken1" 

Number of 

Times an 

Individual Might 

be "Taken" 

Proposed Action Transport 

All Cetacea, all Pinnipedia (including walrus), sea otter, manatee, dugong, and polar bear3

All M/F 

As warranted to 

respond to 

emergencies* 

As warranted to 

respond to 

emergencies* 

Receipt, import/export of samples 

Analytical and diagnostic samples may be transported, imported or exported as needed to laboratories 

Bewathe its posadjwaimp

Project 2: Prospective Health Assessment Research Activities ESA-listed Hawaiian monk seals, and Guadalupe fur seals that are held in captivity and are not releasable back into the wild; and those undergoing rehabilitation 

All M//F 

As warranted to 

satisfy the 

requirements of 

study design 

As warranted to 

satisfy the 

requirements of 

study design 

Capture (net or hand), restraint, handling, tagging, marking (tagging and marking excludes hot branding and would only occur if an animal is not already marked or is not otherwise identifiable), sample collection (including biopsy), release; and acoustic sampling, recording, and playbacks 

None 

Cafacrehcen

Large Whales (gray, right, humpback, fin, blue, sei, Bryde’s, minke, bowhead, and sperm whales) 

All M/F Up to 4,900 annually (total) 5 

Close approach, aerial and vessel surveys (collection of feces, photoidentification for visual health assessment and ID) 

None 

CoEEStaterposadjwa

Large Whales (see above) 

All except 

calves ≤ 6 

months in 

age and 

cows with 

calves (for 

tagging 

and 

sampling) 

M/F Up to 100 annually (total) 5 

Close approach, aerial and vessel surveys; Tagging and sample collection (including biopsy and respiratory gases), acoustic sampling (including recording and playback experiments), collection of feces, photo-identification (for visual health assessment and ID) 

None 

CoEEStaterposadjwa

Large Whales (see above) 

All except 

calves ≤ 6 M/F Up to 400 annually (total) 5 Collection of samples from dead animals in conjunction with the None Co

EE
Table 2. Activities representatives of the National Marine Fisheries Service’s Marine Mammal Health and Stranding Response Program 

conduct on endangered or threatened species under the proposed permit Species Life Stage Gender 

Expected Number 

of Individuals 

"Taken1" 

Number of 

Times an 

Individual Might 

be "Taken" 

Proposed Action Transport 

months in 

age and 

cows with 

calves (for 

“takes” of 

live 

animals) 

activities of other investigators who are operating under other permits or legal authority (subsistence harvest, by-catch); collection of respiratory gasses and blood samples from live animals in conjunction with the activities of 

other investigators who are operating under other permits or legal authority or during Emergency response activities under this permit 

Staterposadjwa

All Cetacea, all Pinnipedia (including walrus), sea otter, manatee, dugong, and polar bear3

All M/F 

As warranted to 

satisfy the 

requirements of 

study design 

As warranted to 

satisfy the 

requirements of 

study design 

Receipt, import/export of samples 

Analytical and 

diagnostic samples 

may be 

transported, 

imported or 

exported as 

needed to 

laboratories 

BeawatwatUS intewor/exp

1 The ESA defines “take” as “harass, harm, pursue, hunt, shoot, would, kill, trap, capture, or collect, or attempt to engage in any such conduct” (16 U.S.C. 1532) 

2. “Emergencies” generally refers to health emergencies involving marine mammals and include, but are not limited to stranding events, entanglements, trauma-rstrikes and gun-shots), oil spills, disease outbreaks, and exposure to biotoxins. Due to their nature, the number of individuals that might be “taken” during respons

cannot be determined in advance 3. dugongs, manatees, polar bears, sea otters, and walruses are under the jurisdiction of the U.S. Fish and Wildlife Service and are not addressed in this biologica
THIS PAGE INTENTIONALLY LEFT BLANK 
APPENDIX J 

CARCASS DISPOSAL INFORMATION

PERSISTENT CONTAMINANTS IN SELECTED SPECIES OF MARINE 

MAMMALS IN US WATERS: 

A REVIEW OF THE LITERATURE FROM 1995 THROUGH 2005 

A report prepared for the 

National Oceanic and Atmospheric Administration, 

National Marine Fisheries Service, Office of Protected Resources 

Marine Mammal Health and Stranding Response Program 

Purchase Order: DG133F03SE1139 

by 

Victoria M. Woshner, DVM, PhD 

August 21, 2006 
REPORT OUTLINE: 

I. INTRODUCTION 

II. ENVIRONMENTAL CONTAMINANTS IN SELECTED MARINE MAMMAL 

SPECIES IN US WATERS 

A. Contaminant classes—background information 

1. Persistent organic pollutants (POPs) 

1. Polychlorinated biphenyls (PCBs) 

2. Polychlorinated dibenzo-p-dioxins and furans (PCDD/Fs) 

3. DDT (1,1,1-trichloro-2,2-bis(p-chlorophenyl)ethane) 

4. Chlordanes (including heptachlor and heptachlor epoxide) 

5. Hexachlorobenzene (HCB) 

6. Hexachlorocyclohexanes (HCHs) 

2. Toxic metals 

1. Cadmium 

2. Lead 

3. Mercury 

4. Organotins 

3. Miscellaneous contaminants 

1. Polybrominated diphenyl ethers (PBDEs) 

2. Polyfluoroalkyls (PFAs) 

B. Concentrations of environmental contaminants in selected species of marine 

mammals in US waters 

1. Species addressed 

2. Databases reviewed, including time period examined and search terms 

used. 

3. Overview of tissue contaminant concentrations: Literature review 

summary 

0. General comments upon format of tables and appendices 

1. Persistent organic pollutants (POPs) 

2. Toxic metals 

3. Miscellaneous contaminants 

C. Conclusions and comments regarding the nature and adequacy of the available 

literature database 

III. LITERATURE CITED 

IV. TABLES AND APPENDICES (ACCOMPANYING EXCEL FILE) 

Table 1. Summary Data for Some Persistent Organic Pollutants, Including PCBs, DDTs, 

Chlordanes, Mirex, Dieldrin, HCHs and HCB in Blubber of Selected Marine 

Mammal Species from US Waters, Reported 1994 through 2005. 

2
Table 2. Metadata for Persistent Organic Pollutants, Including PCBs, DDTs, Chlordanes, 

HCHs and HDB in Selected Marine Mammal Species from US Waters, Reported 

1994 through 2005. 

Table 3. Polychlorinated dibenzo-p-dioxins and -furans (PCDD/Fs) Contaminants in 

Tissues of Selected Marine Mammal Species from US Waters, Reported 1995 

through 2005. 

Table 4. Metadata for Toxic Metal Pollutants, Including Mercury (Hg), Cadmium (Cd), 

Lead (Pb) and Tin (Sn) in Selected Marine Mammal Species from US Waters, 

Reported 1994 through 2005. 

Table 5. Polybrominated Diphenyl Ether (PBDE) Contaminants in Blubber of Selected 

Marine Mammal Species from US Waters, Reported 1995 through 2005. 

Table 6. Polyfluoroalkyl (PFA) Contaminants in Selected Marine Mammal Species in US 

waters, Reported 1995 through 2005. 

Appendix I. Persistent Organic Pollutants, Including Polycholrinated Biphenyls (PCB) 

and Organochlorine Pesticide Contaminants in Selected Cetacean Species in US 

Waters, Reported from 1994 through 2005. 

Appendix II. Persistent Organic Pollutants, Including Polycholrinated Biphenyls (PCB) 

and Organochlorine Pesticide Contaminants in Selected Pinniped Species in US 

Waters, Reported from 1995 through 2005. 

Appendix III. Mercury, Cadmium, Lead and Tin in Tissues of Selected Marine Mammal 

Species from US Waters, Reported 1994 through 2005. 

3
I. INTRODUCTION 

As charismatic megafauna, marine mammals are beloved and revered by people around 

the world. Consequently, mortality events and scientific research involving marine 

mammals are often of a high public profile. Widely publicized reports of high levels of 

anthropogenic contaminants in some whale species have incited concern that the 

carcasses of the whales themselves may constitute a toxicological hazard. This literature 

review was initiated with a view to gathering the collective data pertaining to levels of 

persistent contaminants in that subset of marine mammal species in US waters that tends 

to strand most frequently, so that the potential toxicological hazard generated by 

carcasses of these animals might be assessed. 

II. ENVIRONMENTAL CONTAMINANTS IN SELECTED MARINE MAMMAL 

SPECIES IN US WATERS 

A. Contaminant classes—background information 

II.A.1. Persistent organic pollutants (POPs) 

II.A.1.1. Polychlorinated biphenyls (PCBs) are complex mixtures of synthetic chlorinated 

compounds produced in the US until 1977 for use as insulators, coolants and lubricants, 

particularly in transformers and other electrical equipment (ATSDR, 2000). The basic 

structure of PCBs consists of a biphenyl backbone with 1 to 10 chlorine atoms, yielding 

209 possible PCB congeners. Position and degree of chlorination are important 

determinants of congener toxicity, with more highly chlorinated and coplanar (dioxinlike) PCBs exhibiting greater toxicity than less chlorinated and non-planar congeners. A 

greater degree of chlorination also confers longer environmental persistence, which can 

range from months to years (ATSDR, 2000). The highly lipophilic nature of PCBs allows 

them to accumulate in fatty tissues of organisms or to associate with organic components 

of sediments in environmental samples. In animals and humans, PCBs are toxic to 

integumentary, immune, endocrine, reproductive, and nervous systems. At high doses, 

PCBs have been associated with liver and kidney damage in laboratory animals. PCBs 

are a known animal carcinogen and considered a probable human carcinogen by the US 

Environmental Protection Agency (USEPA) and other agencies (ATSDR, 2000), 

although no increased risk of cancer has been detected in studies of individuals 

occupationally exposed to PCBs (Ross, 2004). PCBs also have been implicated as 

environmental endocrine disruptors in wildlife species (Chiu et al., 2000), although this 

link is controversial (Ross, 2004). While PCBs can persist in the environment for many 

years, they are susceptible to both anaerobic and aerobic microbial degradation via 

metabolism of congeners with higher or lower degrees of chlorination, respectively 

(Abraham et al., 2002). 

II.A.1.2. Polychlorinated dibenzo-p-dioxins (PCDDs) and polychlorinated dibenzo-pfurans (PCDFs) are chlorinated hydrocarbon compounds produced by combustion of 

waste and organic materials, or as contaminants in chemical manufacturing processes. 

Both compound classes consist of two benzene rings joined by either one (PCDFs) or two 

4
(PCDDs) oxygen atoms. Like PCBs, PCDDs/PCDFs are environmentally persistent 

compounds that associate with particulate matter and that are highly lipophilic and prone 

to biomagnify in the food chain. The most toxic PCDD, 2,3,7,8 tetrachlorodibenzo-pdioxin (TCDD) serves as a standard for comparison of other dioxins and dioxin-like 

PCBs, the toxicity of which is sometimes expressed in “toxic equivalency factors” 

(TEQs) of TCDD (ATSDR, 1998). TCDD can cause dermal and hepatic toxicity, and is 

classified as a human carcinogen. Other PCDDs/PCDFs may cause similar effects, 

depending upon their structure (ATSDR, 1998). 

II.A.1.3. DDT (1,1,1-trichloro-2,2-bis(p-chlorophenyl)ethane) is an organochlorine 

pesticide banned in the US in 1972, but still used in many parts of the world for control 

of malaria-transmitting mosquitoes. Technical grade DDT is a mixture of p,p'-, o,p'-D, 

and o,o'-DDT isomers and may also contain DDE (1,1-dichloro-2,2-bis(pchlorophenyl)ethylene) and DDD (1,1-dichloro-2,2-bis(p-chlorophenyl)ethane) as 

contaminants. The latter two compounds may also be produced via metabolism by some 

organisms, including microbes in the environment. In temperate regions, soil half-life of 

DDT is approximately 5 years, but may be up to 4 to 6 times as long, depending on the 

environmental conditions (ATSDR, 2002a). Like other organochlorines, DDT, DDE and 

DDD are extremely lipid soluble, tending to biomagnify and to associate with organic 

matter (soils and sediments) in the environment. At extremely high doses, DDT may be 

neurotoxic (ATSDR, 2002a). DDT and its metabolites are carcinogens and may also act 

as endocrine disruptors, although studies on estrogenic effects of DDT have been 

equivocal (Turusov et al., 2002). 

II.A.1.4. Chlordane is an organochlorine pesticide used in the US until 1988 (ATSDR, 

1994). It is a complex mixture of various chlordane isomers and other compounds, the 

fractions of which vary depending upon the purity of the preparation. The predominant 

components identified in technical chlordane were cis-chlordane, trans-chlordane, transnonachlor, octachlordane, heptachlor, and cis-nonachlor (Dearth and Hites, 1991). 

Chlordane may persist for decades in the environment and is highly lipid soluble, with 

oxychlordane comprising the major metabolite that bioaccumulates in fatty tissues 

(USEPA, 1997). A component of chlordane, heptachlor was also produced and used as a 

pesticide in its own right. Heptachlor epoxide may be produced by degradation or 

metabolism of heptachlor (ATSDR, 1993). Chlordane and the related compounds 

heptachlor and heptachlor epoxide are lipophilic and environmentally persistent 

(ATSDR, 1994 and 1993). At high doses, chlordane may cause toxic effects in the liver, 

digestive tract and nervous system (ATSDR, 1994). While data are limited, heptachlor 

and heptachlor epoxide also have been associated with toxic effects to the nervous and 

reproductive systems, as well as to liver and kidney in humans or animals, with the 

epoxide metabolite being more toxic than its parent compound (ATSDR, 1993). Evidence 

as to carcinogenicity of chlordane is inconclusive (ATSDR, 1994; USEPA, 1997). 

Heptachlor and heptachlor epoxide are considered possible human carcinogens by the 

USEPA, while the International Agency for Research on Cancer (IARC) determined that 

the two compounds are not classifiable with respect to human carcinogenicity (ATSDR, 

1993). 

5
II.A.1.5. Hexachlorobenzene (HCB) was produced in the US until 1970s, although it 

continued to be used as a fungicide until 1984. Also, some HCB is formed as a byproduct in the manufacture of other chlorinated compounds as well as during incineration 

of garbage (McGovern, 2004). HCB is ubiquitous and persistent in the environment, with 

a half-life of up to approximately 6 years in soil, air and surface water, while in 

groundwater the half-life may be almost twice as long. Like other organochlorines, HCB 

is insoluble in water, but highly soluble in organic solvents and lipid allowing it to 

bioaccumulate readily in fatty tissues. HCB is toxic to virtually all organ systems, with 

the central nervous system, ovary and liver comprising the most vulnerable target organs. 

The USEPA classifies HCB as a probable human carcinogen based on data from animal 

studies (ATSDR, 2002b). 

II.A.1.6. Technical grade hexachlorocyclohexane (HCH), which contains α, β, γ, δ, and ε

isomers, was produced in the US until 1983 for use as an insecticide. While other forms 

of HCH are now banned, γ-HCH (also known as lindane) is still imported for use as an 

insecticide and topical treatment for lice (Research Triangle Institute, 1999). At high 

doses, HCHs can result in neural, musculoskeletal and reproductive toxicity. 

Abnormalities in developmental, endocrine, hepatic, renal, immunologic and 

hematopoieitic indices associated with HCH exposure also have been documented in 

humans or animals. Some animal studies have found increased incidence of liver cancer 

in rodents following chronic oral exposure to HCHs, leading the Department of Health 

and Human Services to extrapolate that HCHs may be a possible human carcinogen 

(Research Triangle Institute, 1999). 

II.A.2. Toxic metals 

1. Cadmium 

2. Lead 

3. Mercury 

4. Organotins 

Toxic metals are a unique class of environmental contaminants in that they occur 

naturally, although human activities have allowed them to become more pervasive and 

accessible to biotic cycles. However, because they are innate to the environment, it is 

difficult to distinguish “pollutant” from “natural” sources. Moreover, metals are not 

degraded via microbial or physical action, but may merely metamorphose by alterations 

in oxidation state and/or in the other elements to which they are bound in compounds. 

II.A.2.1. Cadmium is a heavy metal often released as a by-product during refining of 

zinc, copper and lead, and has some industrial uses, such as in batteries and electrical 

components. There also are natural releases of cadmium to the environment through 

events such as volcanic eruptions and forest fires. Compared to other metals, cadmium is 

somewhat unique in that it is taken up and may accumulate to appreciable levels in some 

plants. In animals, cadmium is sequestered in the kidney and liver. The target organ of 

cadmium is the kidney; in addition, it is toxic to a number of other organs, including 

liver, bone and blood vessels. While data are scant, cadmium may be carcinogenic as 

well (ATSDR, 1999a). Various marine mammals are exposed to or bioaccumulate high 

levels of cadmium compared to terrestrial species (Woshner et al., 2001a; 2001b). 

6
Although no physiologic requirement can be demonstrated for cadmium in the majority 

of organisms, some researchers recently have characterized a cadmium-containing 

enzyme in a marine diatom, refuting the long-held belief that cadmium was not only 

universally toxic but also functionless in living creatures (Lane et al., 2005). 

II.A.2.2. Lead is ubiquitous in the environment, both as a result of natural geologic 

distribution and because of wide industrial applications, including former usage as a 

gasoline and paint additive. It is also released by combustion of fossil fuels and waste 

incineration. Lead is believed to be universally toxic, even at very low levels, with no 

organisms known to date demonstrating a physiologic requirement for lead. Generally, 

ingested lead is not well absorbed; however, because it is chemically similar to calcium, 

it may be assimilated and accumulated in tissues in lieu of calcium, particularly in 

growing organisms that are calcium limited. Although the nervous system (particularly 

the developing brain) is considered the “target organ” of lead, this metal is toxic to 

virtually all body systems, including the hematopoietic, cardiovascular, reproductive, 

immune, gastrointestinal, and musculoskeletal systems. Lead is carcinogenic in 

laboratory species, but has not been established as a human carcinogen (ATSDR, 1999b). 

II.A.2.3. Mercury (Hg) is another metal that is apparently toxic to all organisms, even at 

low levels. Relative toxicity of mercury depends largely on the form of the metal (organic 

versus inorganic), and as is the case for all toxicants, the route by which exposure occurs. 

Ingested elemental mercury is not well-absorbed and hence of low toxicity, while 

exposure to methylmercury by this route is highly toxic, as it is almost completely 

absorbed. Like other toxic metals, mercury enters the environment from natural sources, 

such as volcanoes and degassing of the earth’s crust. However, anthropogenic activity has 

dramatically increased mercury emissions, primarily through burning of fossil fuels, as 

well as through mining and other industrial applications. While mercury is toxic to 

virtually all body systems, the nervous system and kidney are the primary target organs 

for organic and inorganic mercury, respectively (ATSDR, 1999c). 

II.A.2.4. In its inorganic form, tin (Sn) is non-toxic. However, organic forms of tin may 

be highly toxic. Organotins have a variety of industrial applications, including use of 

mono- and di-substituted organotins as catalysts and stabilizers in PVC plastics (Appel, 

2004). Tributyl tin (TBT) compounds have been widely used as pesticides, particularly in 

antifouling paints on ships. As such, TBTs are ubiquitous in the aquatic environment, 

even as their use is being phased out due to concerns with respect to their ecotoxicity 

(Rüdel, 2003). As with many other toxicants, organotins adsorb onto organic particulates, 

such that an increase in dissolved organic matter decreases bioavailability of organotins. 

Also, speciation of organotins is pH-dependent; hence, increasing pH is associated with 

formation of organotin hydroxides, which are lipophilic and therefore predisposed to 

bioaccumulate (Fent, 2003). Organotins, especially TBT and triphenyltin (TPT) have 

been associated with tumorigenicity of the adenohypophysis, developmental toxicity, 

reproductive toxicity, neurotoxicity and most especially immunotoxicity, with 

thyrotoxicity apparently consitituting the most sensitive toxic endpoint in mammals 

(Rüdel, 2003). Gastropods are exceptionally vulnerable to toxic effects of TBT, which 

disrupts steroid metabolism leading to development of imposex at even minute 

7
concentrations. In the environment, organotins undergo aerobic degradation, but can 

persist for years in anoxic sediments (Fent, 2004). 

II.A.3. Miscellaneous contaminants 

1. Polybrominated diphenyl ethers (PBDEs) 

2. Polyfluoroalkyls (PFAs) 

II.A.3.1. Polybrominated diphenyl ethers (PBDEs) are one group of brominated flame 

retardants that are currently in wide usage. These compounds are added to plastics, 

particularly those comprising plastic components of computers and televisions as well as 

to plastic foams and textiles (ATSDR, 2002c; Darnerud et al., 2001). While over 200 

PBDE congeners are possible, forms with fewer than four bromine atoms generally are 

not employed in commercial applications. Release of PBDEs into the environment is 

believed to occur primarily through incineration and volatilization; leaching from 

landfills may also serve as a source of PBDE contamination, although studies are lacking 

to verify this (Darnerud et al., 2001). Like other persistent organic pollutants, PBDEs are 

resistant to environmental and biotic degradation. Although research is limited, uptake 

from the environment appears to occur mainly through oral exposure, with absorption 

efficiency inversely related to degree of bromination (ATSDR, 2002c). PBDEs are 

lipophilic, and appear to have potential for both bioaccumulation and biomagnification 

(ATSDR, 2002c). The extent to which PBDEs are metabolized and excreted appears to 

vary with species and degree of congener bromination (Darnerud et al., 2001). In 

laboratory studies, effects of PBDEs range from immunotoxicity and thyrotoxicity, to 

hormone disruption, neurobehavioral abnormalities and developmental toxicity. The 

limited evidence available to date suggests that PBDEs do not have teratogenic or 

genotoxic potential. (ATSDR, 2002c). 

II.A.3.2. Polyfluoroalkyls (PFAs) are a group of compounds comprised chiefly by 

fluorotelomer alcohols and perfluoroalkyl sulfonamide alcohols (as well as their 

breakdown products), that were used in a variety of commodities, including surface 

protectants, paper, insecticides, surfactants, and fire-retardants (Olsen et al., 2003; Seacat 

et al., 2002). Because of their toxicity and environmental persistence, some PFAs have 

been banned (Olsen e al., 2003; Seacat et al., 2002). Through metabolism or 

environmental degradation, fluorotelomer alcohols appear to form carboxylic acids, 

fluorotelomer carboxylic acids (FTCA), and fluorotelomer unsaturated carboxylic acids 

(FTUCA) (Houde et al., 2005). Degradation of perfluoroalkyl sulfonamide alcohols 

yields sulfonic acids (PFSAs) such as perfluorooctane sulfonate (PFOS)—a stable, 

bioaccumulative, toxic end product that has been found among diverse species from 

widely different environments (Giesy and Kannan, 2001). Toxicity of PFOS is related 

primarily to effects on the liver, including hepatocellular hypertrophy and altered lipid 

metabolism, including decreased cholesterol (Olsen et al., 2003). Some PFAs have been 

found to act as hepatic peroxisome proliferators or to provoke developmental and 

neuroendocrine toxicity (Houde et al., 2005). 

8
II.B. Concentrations of environmental contaminants in selected species of marine 

mammals in US waters 

II.B.1. Species addressed 

Twelve species of marine mammals are included in this review, based upon the frequency 

and patterns with which they strand (T. Rowles and J. Whaley, pers. comm.). Species that 

tend to strand as individuals include: pygmy and dwarf sperm whales (Kogia breviceps 

and K. simus, respectively); common bottlenose dolphin (Tursiops truncatus); California 

sea lion (Zalophus californianus); harbor seal (Phoca vitulina); and elephant seal 

(Mirounga angustirostris). Species that tend to strand en masse are represented by: long 

and short-finned pilot whales (Globicephala melas and G. macrorhynchus, respectively); 

rough-toothed dolphin (Steno bredanensis); and white-sided dolphin (Lagenorhynchus 

acutus). Large whale species considered are the gray and humpback whales (Eschrichtius 

robustus and Megaptera novaeangliae, respectively). 

II.B.2. Databases reviewed, including time period examined and search terms used 

The online databases Biological Abstracts, PubMed, and Toxline were searched, using an 

exhaustive list of key words, including (but not limited to): Kogia, Tursiops, Zalophus, 

Phoca, Mirounga, Globicephala, Steno, Lagenorhynchus, Eschrichtius robustus, 

Megaptera, elephant seal, dolphin, marine mammal, pinniped, whale, cetacean, 

polychlorinated biphenyls, PCB, DDT, persistent organic pollutants, pollutant, 

contaminant, heavy metal, mercury, hexachlorocyclohexane, HCB, chlordane, 

heptachlor, dieldrin, aldrin, and organochlorine(s). Reports on marine mammals 

considered for inclusion in this review were confined to those published in peer-reviewed 

journals from 1995 through 2005 that addressed any of the twelve species designated 

above in US waters. A few ancillary studies that were either published prior to 1995, or 

that dealt with marine mammals in non-US waters, were included when those waters 

were contiguous with US waters, and when other US-based studies for those particular 

species were lacking. For example, Varanasi et al., 1994, was published outside of the 

timeframe used as a criterion for inclusion in this review. Nevertheless, I incorporated 

this study, as well as a few other studies (Tilbury et al., 2002; De Luna and Rosales-Hoz, 

2004; Ruelas-Inzunza et al., 2002; Mendez et al., 2002) that addressed contaminants in E. 

robustus from Russian (Bering Sea) and Mexican waters, because contaminant studies for 

gray whales were limited. Also, because gray whales migrate long distances, whales 

studied in Mexican or Russian waters likely navigate US waters as well, where they may 

strand or die and present a carcass disposal problem. 

II.B.3. Overview of tissue contaminant concentrations: Literature review summary 

II.B.3.0. General comments upon format of tables and appendices

This review covers studies done by multiple scientists who were in various geographic 

locations, attempting to answer different research questions, and using diverse techniques 

and laboratories. Consequently the data are quite disparate and difficult to harmonize. For 

9
this reason, and to make this report as pertinent as possible for future applications, I have 

compiled as much data as feasible directly from the source papers. However, whenever 

possible, I attempted to give contaminant concentrations on a wet weight basis (since that 

is the state of the carcass presented for disposal) and to standardize the units in which 

data were given, presenting the persistent organic pollutants, PCDD/Fs, PBDEs, and 

PFAs in ng/g and metals in ug/g. I converted values from ng/g lipid weight to ng/g wet 

weight for Shaw et al, 2005, Struntz et al., 2004, She et al., 2002 and Gautier et al., 1997. 

All tables and appendices (in the accompanying Excel file) contain extensive footnotes to 

accurately characterize the data. In addition, species designations are color-coded in a 

consistent manner throughout the tables and appendices, to allow for easy location and 

comparison of text with respect to a given species. 

II.B.3.1. Persistent organic pollutants (POPs), including PCBs, PCDD/Fs, DDTs, 

Chlordanes, HCB, and HCHs

Because organochlorines, as a class, are lipophilic compounds that might be expected to 

reach highest concentrations in fat (Norstrom, 2002), blubber represents the tissue where 

maximum organochlorine concentrations are likely. Blubber is also the tissue for which 

the most data have been generated pertaining to organochlorine contaminants in marine 

mammals. Reported levels of major persistent organic pollutants (i.e., PCBs, DDTs, 

chlordanes, mirex, dieldrin, aldrin, endrin, HCHs, HCB, and endosulfans) in the selected 

cetacean and pinniped species from US waters are provided in Appendices I and II, 

respectively, and summarized in Table 1, while metadata for studies addressing major 

persistent organic contaminants in the chosen marine mammals is presented in Table 2. 

Twenty-one papers focused on organochlorine contaminants in the cetacean species 

under consideration, while 16 studies examined organochlorines in pinniped species. For 

all contaminant classes combined, the number of studies and the collective number of 

individuals sampled for each cetacean species were as follows: T. truncatus, 9 studies 

(two of which, by Reddy et al. dealt with the same animals), 218 sampled; K. breviceps, 1 

study, 2 sampled; L. acutus, 3 studies (two of which, by Tuerk et al., dealt with the same 

animals), 53 sampled; G. melas, 4 studies, 60 sampled (with some overlap between 

studies and animals, so this number is likely somewhat inflated); S. bredanensis, 2 studies 

(both of which dealt with the same animals), 15 sampled; E. robustus, 3 studies, 101 

sampled (again, there appears to be some overlap between studies and animals, so this 

number likely overstates the true number of animals represented); M. novaeangliae, 2 

studies, 32 sampled. For pinniped species, the number of studies and maximum total 

number of animals sampled were: Z. californianus, 6 studies (Le Boeuf et al., 2002 and 

Kannan et al., 2004 consider the same animals), 148 sampled; P. vitulina, 10 studies, 201 

sampled; M. angustirostris, 4 studies, 13 sampled (Table 2). I found no studies 

addressing organochlorine contaminants in K. simus or G. macrorhynchus in my review 

of the literature. 

Among the species addressed, mean total PCB levels were highest in blubber of T. 

truncatus (240,000 ng/g lipid weight; n=6), which also had the highest single observed 

concentration of total PCBs, at 1,120,000 ng/g lipid weight. P. vitulina had the lowest 

mean concentration of total PCBs (1.7 ng/g wet weight, n=10). Compared to other 

10
species targeted in this review, California seal lions had by far the highest mean blubber 

concentrations of sum DDTs (143,000 ng/g lipid wgt.; n=36) and sum HCHs (780 ng/g 

lipid wgt.; n=36), as well as the highest single observed concentration of these 

contaminants in blubber (1,400,000 and 2,240 ng/g lipid wgt. for sum DDTs and sum 

HCHs, respectively, with the latter value obtained by adding the standard deviation to the 

corresponding mean). Compared to other species, E. robustus (n=38) and K. breviceps

(n=2) had low blubber concentrations of sum DDTs (means of 130 and 540 ng/g wet 

weight, respectively). K. breviceps also had the lowest documented levels of HCHs (1.1 

ng/g wet weight), although little significance can be imparted to a sample consisting of 

two individuals. L. acutus displayed both highest mean and overall blubber 

concentrations of sum chlordanes (8,800 ng/g wet weight; n=23, and 23,900 ng/g wet 

weight, respectively) and dieldrin (1,810 ng/g wet weight; n=23, and 3,940 ng/g wet 

weight, respectively). Tursiops had the lowest mean and overall blubber concentration of 

dieldrin (non-detectable) observed, while the lowest mean blubber concentration of sum 

chlordanes occurred in K. breviceps, followed by E. robustus (50 and 140 ng/g wet 

weight, respectively). The highest mean blubber concentrations of mirex (32,000 ng/g 

wet weight; n=8) and HCB (4,700 ng/g wet weight; n=8) were found in P. vitulina, which 

also had the highest overall blubber concentrations of these two contaminants (60,000 

ng/g wet weight and 8,500 ng/g wet weight for mirex and HCB, respectively). Overall, 

among the species and data represented in this review of the literature, the bottlenose 

dolphin appears to be the cetacean species most contaminated by persistent organic 

pollutants, followed by L. acutus, while among pinnipeds the California sea lion 

represents the most contaminated species, followed by harbor seals. A cursory 

examination of Table 1 reveals that, among the selected cetacean species, E. robustus, K. 

breviceps (represented by only two individuals) and M. novaeangliae appear the least 

contaminated with persistent organic pollutants. Such a perfunctorily apparent inference 

cannot be made with respect to the three pinniped species, however; while blubber 

concentrations of none of the persistent organic pollutants in M. angustirostris exceeds 

the levels in the other two species, neither are they consistently lower than concentrations 

observed in P. vitulina or Z. californianus. 

Collectively, four studies have measured PCDD/Fs in blubber from three of the species 

included in this review (Table 3). For all studies combined, the total number of 

individuals for each species is: E. robustus (n=2), M. angustirostris (n=6), and P. vitulina

(n=75). Two studies, Jarman et al., 1996 and Lake et al., 1995, found no detectable levels 

of PCDD/Fs in blubber of E. robustus (n=2) or P. vitulina (n=15), respectively. The 

highest reported mean concentrations of sum PCDDs and sum PCDFs were 0.279 ng/g 

lipid weight (n=38) and 0.026 ng/g lipid weight=5), respectively, both of which were in 

seals from British Columbia, Canada. 

II.B.3.2. Toxic metals, including Hg, Cd, Pb, and Sn

Twelve studies examined one or more of the toxic metals, Hg, Cd, Pb and Sn, in the 

cetacean species addressed in this review, while only three studies evaluated one or more 

of the metals in question in the selected pinniped species. For all metal contaminants 

combined, the number of studies and the maximum collective number of individuals 

11
sampled for each cetacean species were as follows: T. truncatus, 5 studies, 148 sampled; 

K. breviceps, 1 study, 3 sampled; L. acutus, 1 study, 4 sampled; G. melas, 1 study, 9 

sampled; S. bredanensis, 1 study, 15 sampled; and E. robustus, 5 studies, 35 sampled. 

Similarly for pinniped species, the number of studies and total number of animals 

sampled were: Z. californianus, 1 study, 10 sampled; P. vitulina, 2 studies, 13 sampled; 

M. angustirostris, 2 studies, 6 sampled. No studies were found that addressed levels of 

the specified metal contaminants in G. macrorhynchus, M. novaeangliae, or K. sima

between 1995 and 2006 in US waters. Metadata describing studies pertaining to the 

potentially toxic metals Hg, Cd, Pb and Sn are summarized in Table 4, while reported 

levels of these metals in the given species over the publication timeframe under 

consideration are given in Appendix III. 

It is difficult to make any generalizations or to draw any meaningful comparisons about 

the four potentially toxic metals covered by this literature review, because reported data 

is quite limited and methodologies between studies vary. Overall, ten studies report 

values on a wet weight basis, while the remaining five present metal concentrations on a 

dry weight basis, and since raw data generally are not provided, the reader cannot convert 

data from one form to the other. 

II.B.3.3. Miscellaneous contaminants: PBDEs and PFAs

Within the geographic and temporal confines of this review, 6 studies have evaluated 

concentrations of PBDEs in the selected species of marine mammals (Table 5). Four 

studies examined PBDEs in blubber of Tursiops, L. acutus, S. bredanensis and P. 

vitulina, while the remaining two studies addressed PBDE levels in P. vitulina blood. 

Among the species in these studies, adult male Tursiops demonstrated the highest PBDE 

contamination, with a mean concentration of 3,110 ng/g wet weight in blubber (range: 

126–16300, n=9). 

As for PBDEs, PFAs have been assessed in a limited number of individuals and species 

(Table 6). Kannan et al., 2001 analyzed hepatic concentrations of PFOS in the following 

species: K. breviceps (n=2), S. bredananensis (n=2), T. truncatus (n=20), Z. califonianus

(n=6), M. angustirostris (n=5), P. vitulina (n=3). Houde et al. (2005) conducted a more 

extensive study of various PFA compounds in Tursiops blubber and found concentrations 

of mean sum PFAs ranging from 778 (n=42) to 1738 (n=47) ng/g wet weight between 

geographic locations on the eastern US coast. 

II.C. Conclusions and comments regarding the nature and adequacy of the available 

literature database 

The studies encompassed by this literature review were conducted to determine 

concentrations of specific environmental contaminants in various given marine mammal 

species. Such monitoring investigations generally are undertaken to learn how 

environmental contaminants may be impacting individual or population health, as well as 

to indicate whether environmental contaminants might be implicated as a causative factor 

in stranding events. Tursiops is, by far, the species for which the most comprehensive 

12
data exist pertaining to contaminants, and among those contaminants, PCBs have been 

the most widely analyzed in this species. Of nine studies that sampled a combined total of 

218 bottlenose dolphins for PCBs, seven studies evaluated PCBs in blubber, with a 

combined total sample size of 210 animals. Of these 210 dolphin blubber samples, 129 

appear to have been obtained via biopsy, while 81 were apparently from stranded 

animals. Eighty-one of the 210 blubber samples were taken from dolphins in the Gulf of 

Mexico, off the FL (including Sarasota Bay), TX, or AL coasts. Sixty-two blubber 

samples were from Atlantic dolphins, generally from three sites: Beaufort, NC, (n=40) 

Charleston Bay, SC, (n=11) and Indian River Lagoon, FL (n=17). The remaining 14 

blubber samples were from dolphins in San Diego Bay, CA. The blubber PCB data 

reported among the seven studies is in a variety of formats. Hansen et al., (2004) reported 

the geometric means of their data, while Wells et al., (2005) did not report means at all. 

Other studies reported arithmetic means. The number of PCB congeners which comprise 

“sum PCBs” among these seven studies also vary widely, from ten to eighty-seven 

congeners, while three studies did not report the identity or number of congeners 

analyzed. All seven studies report PCB concentrations on a lipid weight basis. However, 

if the concern is not the consequences of PCB contamination on the dolphin itself, but 

rather the dispersion of the PCBs contained within the blubber throughout the 

environment during carcass decomposition or scavenging, the entity of interest is the 

level of contamination expressed on a wet weight basis. Because individual animal data 

including blubber percent lipid are not specified in any of these seven studies, conversion 

of concentration data to a wet weight basis is not possible. 

Sampling techniques also influence the levels of organochlorines measured in blubber. Of 

the seven studies that quantified blubber PCBs, only two (Salata et al., 1995 and Finklea 

et al., 2000) stipulated that full-thickness blubber samples were obtained. Kuehl and 

Haebler (1995) and Johnson-Restrepo (2005) did not specify how blubber samples were 

taken. The remaining three research teams employed biopsy methods, including remote 

dart (Hansen et al., 2004), punch (Reddy et al., 2001) and wedge (Wells et al., 2005) 

biopsy. All of these biopsy techniques are inherently biased towards collection of the 

outermost portion of the blubber. However, Aguilar and Borrell (1991) and Severinsen et 

al., (2000) documented that organochlorines are not homogenously distributed 

throughout this tissue in species of two baleen whales and a phocid seal, respectively, but 

rather stratified such that contaminant levels in the outermost blubber are significantly 

greater than that of the innermost blubber layer. Moreover, this difference was not 

attributable merely to variation in lipid content (Severinsen et al., 2000). Struntz et al., 

2004 noted the heterogeneous morphological and histological structure of Tursiops

blubber. Consequently, it would be imprudent to assume that PCBs or other 

organochlorine contaminants are homogenously dispersed throughout blubber of 

bottlenose dolphins. Rather, contaminants concentrations obtained from blubber biopsy 

specimens likely overestimate blubber contaminant burdens, and should be interpreted 

with caution. 

The above summary briefly illustrates the extremely limited nature of the database for the 

most thoroughly studied species and contaminant combination (Tursiops and PCBs) 

among those considered by this review. For other contaminants and species, the data are 

13
even scantier. Certain generalizations might be made about the distribution of particular 

contaminants within tissues, and among individuals in a given population. For example, it 

is generally understood that species higher trophic species such as dolphins are more 

prone to bioaccumulating higher levels of some contaminants than species that feed at 

lower trophic levels, such as baleen whales. Also, lipophilic contaminants such as PCBs 

tend to be at highest levels in blubber of adult males, because contaminant levels increase 

with age, and because females can depurate some of their acquired contaminant load 

through transfer to offspring (Wells et al., 2005). This latter phenomenon accounts for the 

observation that immature animals may have higher blubber PCB concentrations than 

adults, when levels are evaluated on a lipid weight basis. Despite such documented 

patterns of PCB accumulation within Tursiops, overall the data are quite limited with 

respect to samples sizes, tissues analyzed and geographic locations represented. 

Contaminant monitoring studies tend to focus on tissues that represent target organs of a 

given toxicant or are sites of bioaccumulation. Because few tissues are assayed, there is 

generally insufficient information to infer the total body burden of a given contaminant 

for an individual in a given population. Moreover, patterns of contaminant accumulation 

will vary based upon exposures. Individuals from highly contaminated areas will not 

serve to represent animals from less contaminated regions, and vice versa. The 

heterogeneous nature of contaminants data published for the selected marine mammals in 

US waters encompassed by this review make it difficult to compare between studies, 

much less to unify this disparate research into an assemblage with utility for other 

applications such as the evaluation of the potential toxicological environmental hazards 

posed by decomposing carcass. At current, the database for the contaminants in the 

species encompassed by this review is inadequate to support such an assessment. 

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22
Table 1. Summary of Concentrations of Major Organochlorine Contaminant Classes in Blubber of Selected Marine Mammal Species from US Waters as Report

Table 1. Summary Data for Some Persistent Organic Pollutants, Including PCBs, DDTs, Chlordanes, Mirex, Dieldrin, HCHs and HCB in Blubber of SeMarine Mammal Species from US Waters, Reported 1994 through 2005. For each species, the lowest and highest overall means among reported studies are given, followed by the corresponding sample size, as well as ovranges for animals in all studies combined.CETACEAN

S

Analyte (ng/g) Lipid (%)

∑ PCBs

∑ DDTs

∑ chlordanes mirex dieldrin

∑ HCHs H

T. truncatusa Lowest mean (n) 19.9 (4) 5644 (6) 3988 (6) 548 (6) 20.3 (2) ND (2) 109 (33) N

Highest mean (n) 39.4 (9) 240000 (6) 51906 (5) 7022 (5) 663 (4) 1550 (5) 234 (14) 33Overall range 1.2 - 82.8 420 - 1120000 428 - 87281 195 - 10553 ND - 6540 ND - 3120 9 - 354 ND 

K. brevicepsc Mean (n) 3.4 (2) 560 (2) 540 (2) 50 (2) NA NA 1.1 (2) 5

Overall range 2.6 - 4.1 290 - 830 400 - 680 27 - 73 NA NA 1.1 - 1.1 1.4 

L. acutusc Lowest mean (n) 43.8 (6) 9410 (9) 4090 (9) 2200 (9) 40.4 (9) 293 (9) 91 (9) 50

Highest mean (n) 43.8 (6) 29400 (23) 15900 (23) 8800 (23) 73.7 (15) 1810 (23) 301 (23) 23Overall range 17.2f 490 - 62700 498 - 43300 285 - 23900 18.4 - 112 62.6 - 3940 50.4 - 821 11d 

G. melasc Lowest mean (n) 39 (16) 4172 (11) 6000 (16) 1221 (11) 27 (11) 262 (7) 57.5 (11) 20

Highest mean (n) 75 (16) 12000 (6) 18336a (16) 3000 (6) 56a (16) 441 (11) 104a (16) 37

Overall range 17.7d - 88 1087d - 25000 NDa,d - 42046a,e 55a,d - 5800 NDc,d - 90a,e 56.8 - 674e NDc,d - 157a,e NDa

S. bredanensisc Mean (n) 53 (15) 18392 (15) 9285.5 (15) 3825 (15) 269.3 (15) 233.8 (15) 26.0 (15) 28

Overall range 38 - 73.3 643 - 43301 146 - 23139 74.1 - 2093 16.4 - 664 9.03 - 1220 2.6 - 177 0.4 

E. robustusc Lowest mean (n) 8.5 (22) 220 (38) 130 (38) 140 (17) NA NA NA 10

Highest mean (n) 48 (17) 1600 (22) 444 (22) 340 (22) NA 160 (22) NA 51Overall range 0.6 - 73 120 - 10000 11 - 2940 13 - 2200 ND - 100 4 - 1600 NA 17 

M. novaeangliaec Lowest mean (n) NA 897a (12) NA NA 1.8 (6) 308 (6) 104 (6) 73

Highest mean (n) 44.9 (7) 1153 (7) NA 385.6 (6) 7.2a (12) 363.4a (13) 108.1a (12) 172

Overall range 27 - 63 301a,d - 2958 NA 125.6 - 728.3 ND - 11.1a,e 52.7 - 777 33.8 - 242 15.8 

PINNIPEDSZ. californianusc Lowest mean (n) 4.2 (9) 1300 (5) 13947 (9) 457 (9) NA NA 57 (9) 

Highest mean (n) 50 (36) 48158 (12) 143000a,h (36) 3420a (36) NA 190a (36) 780a (36) Overall range 1 - 88 ND - 410000a 456 - 1400000a 17 - 9450 NA 220f 6.5 - 2240a,e 

M. angustirostrisc Lowest mean (n) 74 (4) 550 (6) 11000a (2) 1095a (2) NA NA 122a (2) 3

Highest mean (n) 85 (2) 6979 (4) 12418 (4) 1118 (4) NA 28a (2) 184 (4) 32

Overall range 18 - 93 460d - 10440 3000a - 19800 290a - 1900a NA 19a - 37a 44a - 279 14.

P. vitulinac Lowest mean (n) 40 (3) 1.7 (10) 314 (5) 205 (5) 4.9 (3) 5 (5) 33a (2) 5

Highest mean (n) 89 (2) 40376 (3) 8790 (3) 4015 (3) 32000 (8) 364a (4) 220a (4) 47

Overall range 16 - 95 ND - 78474 130 - 13612 80 - 8938 1.2 - 60000 3 - 1060a 22.4a - 425a 2.79

Abbreviations: ND, the analyte was not detected above the limit of detection; NA, not available

ang/g lipid weightbLargest sample with this meancng/g wet weightdValue obtained by subtracting the SD from the corresponding meaneValue obtained by adding the SD to the corresponding meanfStandard deviation of mean abovegND in either of two studies that address this analyteh

∑DDTs refers to p,p' forms of DDE, DDD and DDT only
Table 2. Metadata for Persistent Organic Pollutants, Including PCBs, DDTs, Chlordanes, HCHs and HDB in Selected Marine Mammal Species from US 

Waters, Reported 1994 through 2005.

An "X" in a given contaminant column denotes that contaminant was analyzed. 

Source Species Contaminant Classes Analyzed PCBs (# of congeners) DDTs Chlordanes* HCHs HCBTissue (n) Date Sampled Event Location Source data 

characterization

Arith.(A) or Geo. (G) 

Mean; lw or ww; % lipid 

given?; individual animal 

data provided?

CETACEANS

Hansen et al., 2004 T. truncatus X (15) X X X blubber (62) 1995-2000 B NC, SC, FL G; lw; yes; no

Reddy et al., 2001; 1998 T. truncatus X (10) X X X X blubber (14)

blood (16)

1994 B CA NR; lw; no; yes

Salata et al., 1995 T. truncatus X (NR) X X X X blubber (33) NR S TX, FL A; lw; no; no

Kuehl & Haebler, 1995 T. truncatus X (NR) Xa X X blubber (24) 1990 S TX, FL A; lw; no; no

Finklea et al., 2000 T. truncatus X (87) blubber (10) 1990 S TX A; lw; no; yes

Johnson-Restrepo et al., 2005 T. truncatus X (NR) blubber (20) 1991-2004 S & Bd FL A; lw; yes; no

Wells et al., 2005 T. truncatus X (22) blubber (47)

blood (NR)

milk (NR)

2000-2001 B FL NRf

; lw; no; no

Watanabe et al., 2000 T. truncatus X (35) Xa X X X liver (6) 1989-94 S FL A; ww; yes; yes

K. breviceps X (35) Xa X X X liver (2) 1991-92 S FL A; ww; yes; yes

Tuerk et al., 2005a,b L. acutus X(55) X X X X blubber (47) 1993-2000 S MA A;ww; no; no

Weisbrod et al., 2001 L. acutus X (27) X X X X blubber (6)

skin (6)

liver (6)

lung (2)

kidney (2)

1994-96 S MA, NY A; ww; yes; no

G. melas X (27) X X X X blubber (11)

skin (3)

liver (8)

heart (4)

muscle (6)

kidney (3)

testis (1)

1990-96 S MA, NY A; ww; yes; no

Weisbrod et al., 2000 G. melas X (27) X X X X blubber (16)

liver (17)

1990-96 S MA A; lw; yes; no

Becker et al., 1997 G. melas X (33) X X X blubber (7) NRb NRb MA A; ww; no; no

Tilbury et al., 1999 G. melasb X (17) X X X blubber (22)

liver (25)

kidney (9)

brain (8)

ovary (2)

1986-90 S MA A; ww; yes; no

Struntz et al., 2004; Tuerk et 

al., 2005a

S. bredanensis X (33) X X X X blubber (15) 1997 S FL A; lw; yes; yes

Varanasi et al., 1994 E. robustus X (NR) X X X blubber (22)

liver (10)

brain (1)

1988-91 S CA, WA & AK Ac

; ww; yes; no 

Tilbury et al., 2002 E. robustus X (17) X X X blubber (17)

liver (14)

kidney (6)

brain (6)

muscle (3)

1994 H Russia 

(Western Bering 

Sea)

A; ww; yes; no

Krahn et al., 2001 E. robustusb X (17) X X X blubber (62) 1996 & '99 B & S WA A; ww; yes; no

Metcalfe et al., 2004 M. novaeangliae X (25) Xa X X X blubber (25) 1993-99 B Canada A; lw; no; no

Gauthier et al., 1997 M. novaeangliae X (19) Xa X X X blubber (7) 1991 B Canada A; lw; yes; yes

PINNIPEDS

Lieberg-Clark et al., 1995 Z. californianus --- Xa blubber (7) 1988-92 S CA G; ww; no; no

Hayteas & Duffield, 1997 Z. californianus X (NR) Xa blubber (5) 1991-95 S OR G; ww; no; yes

P. vitulina X (NR) blubber (10) 1991-95 S OR G; ww; no; yes

M. angustirostris X (NR) blubber (1) 1991-95 S OR G; ww; no; yes

Kajiwara et al., 2001 Z. californianus X (NR) Xa X X X blubber (12)

liver (9)

1991-97 S CA A; ww; yes; yes

P. vitulina X (NR) Xa X X X liver (10) 1991-97 S CA A; ww; yes; yes

M. angustirostris X (NR) Xa X X X blubber (4) 1991-94 S CA A; ww; yes; yes

Kannan et al., 2004; 

Le Boeuf et al., 2002

Z. californianus X (NR) Xa X X blubber (36) 2000 S CA A; lw; yes; no

M. angustirostris X (NR) Xa X X X blubber (2) 2000 S CA A; lw; yes; no

Lake et al., 1995 P. vitulina X (18) Xa X X blubber (9)

liver (9)

1990-92 S NY, MA A; ww; no; no

Young et al., 1998 P. vitulina X (20) blood (16) 1990 S CA A; ww; no; no

Hong et al., 1996 P. vitulina X (73)

X (54)

Xa X blubber (8)

liver (8)

1990 S WA A; ww; no; no

Krahn et al., 1997 P. vitulina X (17) X X X blubber (15) 1992-93 S & H WA, OR, AK Af

; ww; yes; nof

Ross et al., 2004 P. vitulina X (109) blubber (60) 1996-97 B Canada; WA A; lw; no; no

Neale et al., 2005a P. vitulina X (10) Xe blood (17) 2001-02 B CA A; ww & lw, no, no

Neale et al., 2005b P. vitulina X (11) Xe blood (35) 2001-02 B CA NR; ww & lw; no; no

Shaw et al., 2005 P. vitulina X (20) X X X X blubber (30) 2001-02 S MA, ME, NH, NYA; lw; yes; yes

Debier et al., 2005a M. angustirostris X (141) blubber (6) 2002 B CA A; lw & ww; yes; no

Debier et al., 2005b Z. californianus X (NR) X serum (12) 2002 B CA A; ww & lw; yes; no

Ylitalo et al., 2005 Z. californianus X (17) X blubber (76) 1993-2003 S CA A; ww & lw; yes; no

Abbreviations: NR, not reported; S, stranded; B, biopsied; H, subsistence harvest; A, arithmetic mean; G. geometric mean; lw, reported on a lipid weight basis; 

ww, reported on a wet weight basis

*Number of chlordane isomers analyzed varied between studies

a

Only p'p' isomers of DDT, DDE and DDD were analyzed; in some studies, not all three p',p' isomers were analyzed. b

In Appendix I, see footnotes "g," "h" and "j" for Becker et al.(1997),Tilbury et al.(1999) and Krahn et al. (2001), respectively, regarding study overlap c

Means exclude values below limit of detection d

From archived samples; from source text it appears that 14 are from stranded dolphins and the remaining 6 were biopsies 

e

4,4' DDE only

f

Ranges only were given for data (except for some data subsets in Wells); data provided in graphic format only
7

Table 3. Polychlorinated dibenzo-p-dioxins and -furans (PCDD/Fs) Contaminants in Tissues of Selected Marine Mammal Species from US Waters, R

Source: Jarman et al., 1996 Source: Ross et al., 2004 Source: Lake et al., 199Event: Stranding Event: Biopsy Event: Stranding Location: British Columbia, Canada (Vancouver Is. & Denman Is.)

Location: BC, Canada (Queen Charlotte Strait)

Location BC, Canada (Strait of Georgia)

Location: WA (Puget Sound)

Location: NY & MA 

Date Sampled: 1987-88 Date Sampled: 1996-9 Date Sampled: 1996-97 Date Sampled: 1996-97 Date Sampled: 1990-92 Species: Eschrichtius robustus Species: Phoca vitulina Species: Phoca vitulina Species: Phoca vitulina Species: Phoca vitulina Tissue: Blubber Tissue: Blubber Tissue: Blubber Tissue: Blubber Tissue: Blubber 

Analyte (ng/g wet weight) n Mean LODb n Meana,c SE n Meanc SE n Meanc SE n 

2,3,7,8-TCDD 2 ND <2 15d

1,2,3,7,8-PnCDD 2 ND <5 15d1,2,3,4,7,8-HxCDD 15d1,2,3,6,7,8-HxCDD 2 <8 15d 

1,2,3,7,8,9-HxCDD 2 ND <8 15d

1,2,3,4,6,7,9-HpCDD 2 ND <101,2,3,4,6,7,8-HpCDD 2 ND <10 15d 

OCDD 2 ND <20 15d ∑ 2,3,7,8-PCDDs 5 0.072 0.006 38 0.256 0.031 17 0.119 0.011∑ PCDDs 5 0.096 0.01 38 0.279 0.032 17 0.119 0.016 

2,3,7,8-TCDF 2 ND 3 15d

1,2,4,7,8-PnCDF 2 ND <51,2,3,7,8-PnCDF 15d2,3,4,7,8-PnCDF 2 ND <5 15d 

1,2,4,8,9-PnCDF 2 ND <51,2,4,6,8,9-HxCDF 2 ND <81,2,3,4,7,8-HxCDF 15d

1,2,3,6,7,8-HxCDF 15d1,2,3,7,8,9-HxCDF 15d2,3,4,6,7,8-HxCDF 15d1,2,3,4,6,9-/1,2,3,6,8,9-HxC 2 ND <81,2,3,4,6,8,9-HpCDF 2 ND <101,2,3,4,6,7,8-HpCDF 15d1,2,3,4,7,8,9-HpCDF 15dOCDF 15d 

∑ 2,3,7,8-PCDFs 5 0.022 0.002 38 0.016 0.002 17 0.01 0.001∑ PCDFs 5 0.026 0.004 38 0.025 0.013 17 0.01 0.001 

Abbreviations: ND, the analyte was not detected above the limit of detection; SE, standard error of the mean; SD, standard deviation; NR, not reported

aArithmeticbLOD-limits of detection for individual PCDD/F congenerscng/g lipid weightdAll samples were near or below limits of detection (3-5 pg/g).eOn a wet weight basis means (SD) were: 0.025(0.017) and 0.014(0.004) for ∑ PCDDs and ∑ PCDFs, respectively.
Table 4. Metadata for Toxic Metal Pollutants, Including Mercury (Hg), Cadmium (Cd), Lead (Pb) and Tin (Sn) in Selected Marine Mammal Species from US Waters, 

Reported 1994 through 2005.

An "X" in a given metal contaminant column denotes that metal was analyzed.

Metal Contaminant Analyzed

Source Species Mercury Cadmium Lead Tin Tissue (n) Date Sampled Event Location Comments

CETACEANS

Ruelas-Inzunza et al., 2002 E. robustus X (THg & MeHg) X X Kidney (4)

Liver (4)

Muscle (4)

1999 S Mexico (Gulf of 

California)

DW

Tilbury et al., 2002 E. robustus X (THg) X X Brain (6)

Kidney (6)

Liver (5)

1994 H Russia (NW 

Bering Sea)

WW

Varanasi et al., 1994 E. robustus X (THg) X X Xa Brain (1)

Kidney (10)

Liver (10)

1988-1991 S CA, WA & AK WW

De Luna & Rosales-Hoz, 2004 E. robustus X Bone (8)

Epidermis (8)

Kidney (2)

Muscle (8)

1999 S Mexico (Ojo de 

Liebre Lagoon)

DW

Mendez et al., 2002 E. robustus X X Blubber (5)

Heart (7)

Kidney (5)

Liver (5)

Lung (7)

Muscle (5)

1999 S Mexico 

(Sinaloa & Baja 

California Sur)

DW

Mackey et al., 1995 G. melas X (THg) X Liver (9) 1990-1990 S MA WW

L. acutus X (THg) X Liver (4) 1993 S MA WW

Beck et al., 1997 T. truncatus X (THg) X X Liver (34) NR S SC WW

Kuehl & Haebler, 1995 T. truncatus X (THg) X X Liver (24) 1990 S TX & AL (Gulf 

of Mexico)

WW

Meador et al., 1999 T. truncatus X (THg & MeHg) Xc Xc Blubber (4)

Kidney (30b

)

Liver (30b

)

1990-1991 S TX DWf

T. truncatus X (THg & MeHg) Xc Xc Kidney (13b

)

Liver (14b)

1990-1991 S FL DW

Wood & Van Vleet, 1996 T. truncatus X Kidney (21)

Liver (29)

Muscle (21)

1990-1994 S FL DW

Kannan et al., 1997 T. truncatus Xd Blubber (1)

Brain (1)

Heart (1)

Liver (16)

Kidney (17)

Melon (1)

Muscle (11)

1989-1994 S FL WW

K. breviceps Xd Kidney (2)

Liver (3)

Muscle (2)

1989-1994 S FL WW

Mackey et al., 2003

S. bredanensis

X (THg) X Xe Kidney (15)

Liver (15)

1997 S FL (Gulf of 

Mexico)

WW

PINNIPEDS

Lake et al., 1995 P. vitulina X (THg) Liver (7) 1990-1992 S NY & MA WW

Owen & Flegal, 1998 M. angustirostris X Blood (4) 1994-1995 B CA WW

Kajiwara et al., 2001 M. angustirostris Xd Liver (2) 1991-1994 S CA WW

P. vitulina Xd Liver (6) 1991-1997 S CA WW

Z. californianus Xd Liver (10) 1991-1997 S CA WW

Abbreviations: THg, Total mercury; MeHg, organic (methyl) mercury; NR, not reported; S, stranded; B, biopsied; H, subsistence harvest; WW, reported on a wet weight basis; 

DW, reported on a dry weight basis

a

Total tin was analyzed in kidney and liver of seven animals b

Maximum analyzed for this tissue at this location c

Analyzed in kidney and liver only d

Sum of butyltins, including mono-, di- and tri-butyltin e

Total tin

f

Except for blubber, which was reported as WW
Appendix III. Mercury, Cadmium, Lead and Tin in Tissues of Selected Marine Mammal Species from US Waters, Reported 1994 through

2005. All concentrations are reported on a wet weight basis, except where noted otherwise by an asterisk*. Mercury (Hg) Species Tissue 

Mean 

ug/g Min. Max. n Location 

Date 

Sampled Event Ref

E. robustus kidneya 277* 140j NR 4 

Mexico (Gulf of California) 1999 Stranding 

Rue200

E. robustus kidneyb 51* 22j NR 4 Mexico (Gulf of California) 1999 Stranding Rue

200

E. robustus livera 185* 82j NR 4 Mexico (Gulf of California) 1999 Stranding Rue

200

E. robustus liverb 42* 34j NR 4 Mexico (Gulf of California) 1999 Stranding Rue

200

E. robustus musclea 145* 82j NR 4 Mexico (Gulf of California) 1999 Stranding Rue

200

E. robustus muscleb 109* 40j NR 4 Mexico (Gulf of California) 1999 Stranding Rue

200

E. robustus braina 0.022 0.002h NR 6g Russia (NW Bering Sea) 1994 

Subsistence harvest Tilb

E. robustus kidneya 0.034 0.001h NR 6g Russia (NW Bering Sea) 1994 

Subsistence harvest Tilb

E. robustus livera 0.16 0.061h NR 5g Russia (NW Bering Sea) 1994 

Subsistence harvest Tilb

E. robustus braina ND ND ND 1 CA, WA & AK 1988-91 Stranding VarE. robustus kidneya 0.034 ND 0.06 10 CA, WA & AK 1988-91 Stranding VarE. robustus livera 0.056 0.009 0.12 10 CA, WA & AK 1988-91 Stranding VarG. melas livera 40.3 1.00 112.0 9 MA 1990-91 Stranding MacL. acutus livera 10.36 1.00 22.70 4 MA 1993 Stranding MacS. bredanensis kidneya 5.8 0.9 15 15 FL (Gulf of Mexico) 1997 Stranding MacS. bredanensis livera 70 3.4 235 15 FL (Gulf of Mexico) 1997 Stranding MacT. truncatus livera 17.8 <0.5 146.5 34 SC NR Stranding BecT. truncatus livera 0.96 0.15 2.23 5o TX & AL (Gulf of Mexico) 1990 Stranding KueT. truncatus livera 4.39 1.72 8.36 5g TX & AL (Gulf of Mexico) 1990 Stranding KueT. truncatus livera 45.5 5.1 87.8 9p TX & AL (Gulf of Mexico) 1990 Stranding KueT. truncatus livera 25.9 6.1 48.7 5q TX & AL (Gulf of Mexico) 1990 Stranding KueT. truncatus blubberb 0.6 0.4 0.7 4 FL 1991-92 Stranding MeaT. truncatus kidneya 33* 1.0 89 29 TX 1991-92 Stranding MeaT. truncatus kidneya 68* 11.2 110 12 FL 1991-92 Stranding Mea
Mercury (Hg) (continued) 

Species Tissue 

Mean 

ug/g Min. Max. n Location 

Date 

Sampled Event Ref

T. truncatus kidneyb 4.5* 1.3 10.4 23 TX 1991-92 Stranding MeaT. truncatus kidneyb 9.9* 1.4 19 13 FL 1991-92 Stranding MeaT. truncatus livera 212* 8.3 1404 30 TX 1991-92 Stranding MeaT. truncatus livera 304* 18 1312 13 FL 1991-92 Stranding MeaT. truncatus liverb 6* 0.9 23 24 TX 1991-92 Stranding MeaT. truncatus liverb 11* 2.5 24 14 FL 1991-92 Stranding MeaP. vitulina livera 38.5 31.6 49.3 4 NY & MA 1990-92 Stranding LakP. vitulina livera 69.9 16.0 138 3 NY & MA 1990-92 Stranding Lak

Cadmium (Cd) Species Tissue 

Mean 

ug/g Min. Max. n Location 

Date 

Sampled Event Reference 

E. robustus blubber 0.16* ND 0.16 5g

Mexico (Sinaloa & Baja California Sur) 1999 Stranding Mendez et al., 2002 

E. robustus heart 0.68* 0.16 1.81 7g

Mexico (Sinaloa & Baja California Sur) 1999 Stranding Mendez et al., 2002 

E. robustus kidney 15.4* 1.93 35.1 5g

Mexico (Sinaloa & Baja California Sur) 1999 Stranding Mendez et al., 2002 

E. robustus liver 1.77* 0.81 3.62 5g

Mexico (Sinaloa & Baja California Sur) 1999 Stranding Mendez et al., 2002 

E. robustus lung 1.16* 0.1 5.26 7g

Mexico (Sinaloa & Baja California Sur) 1999 Stranding Mendez et al., 2002 

E. robustus muscle 0.86* 0.05 2.34 5g

Mexico (Sinaloa & Baja California Sur) 1999 Stranding Mendez et al., 2002 

E. robustus kidney 5.7* 1.4j 8.0 4 Mexico (Gulf of California) 1999 Stranding 

Ruelas-Inzunza & PaezOsuna, 2002 

E. robustus liver 1.1* 1.0j NR 4 Mexico (Gulf of California) 1999 Stranding 

Ruelas-Inzunza & PaezOsuna, 2002 

E. robustus muscle 0.4* 0.2j NR 4 Mexico (Gulf of California) 1999 Stranding 

Ruelas-Inzunza & PaezOsuna, 2002 

E. robustus brain 0.1 0.01h NR 6g Russia (NW Bering Sea) 1994 

Subsistence harvest Tilbury et al., 2002i
Cadmium (Cd) (continued) 

Species Tissue 

Mean 

ug/g Min. Max. n Location 

Date 

Sampled Event Reference 

E. robustus kidney 0.59 0.11h NR 6g Russia (NW Bering Sea) 1994 

Subsistence harvest Tilbury et al., 2002i

E. robustus liver 0.21 0.04h NR 5g Russia (NW Bering Sea) 1994 

Subsistence harvest Tilbury et al., 2002i

E. robustus brain 0.02 0.02 0.02 1 CA, WA & AK 1988-91 Stranding Varanasi et al., 1994 E. robustus kidney 4.1 0.14 6.1 10 CA, WA & AK 1988-91 Stranding Varanasi et al., 1994 E. robustus liver 4.3 0.06 6.2 10 CA, WA & AK 1988-91 Stranding Varanasi et al., 1994 G. melas liver 7.88 2.8 14.3 9 MA 1990-91 Stranding Mackey et al., 1995 L. acutus liver 0.42 0.24 0.86 4 MA 1993 Stranding Mackey et al., 1995 S. bredanensis kidney 1.73 0.05 3.94 15 FL (Gulf of Mexico) 1997 Stranding Mackey et al., 2003 S. bredanensis liver 0.54 0.01 1.02 15 FL (Gulf of Mexico) 1997 Stranding Mackey et al., 2003 T. truncatus liver 0.051 0.009 0.27 34 SC NR Stranding Beck et al., 1997 T. truncatus liver 0.06 0.01 0.08 5o TX & AL (Gulf of Mexico) 1990 Stranding Kuehl & Haebler, 1995 T. truncatus liver 0.11 0.08 0.16 5g TX & AL (Gulf of Mexico) 1990 Stranding Kuehl & Haebler, 1995 T. truncatus liver 0.43 0.10 1.34 9p TX & AL (Gulf of Mexico) 1990 Stranding Kuehl & Haebler, 1995 T. truncatus liver 0.31 0.11 0.64 5q TX & AL (Gulf of Mexico) 1990 Stranding Kuehl & Haebler, 1995 T. truncatus kidney 1.9* ND 4.2 

30 (11 

ND) TX 1991-92 Stranding Meador et al., 1999c,d

T. truncatus kidney 4.4* ND 5.2 13 (5 ND) FL 1991-92 Stranding Meador et al., 1999c,dT. truncatus liver 0.32* ND 0.7 14 (8 ND) TX 1991-92 Stranding Meador et al., 1999c,dT. truncatus liver 1.6* ND 1.6 

11 (10 

ND) FL 1991-92 Stranding Meador et al., 1999c,d

T. truncatus kidney 1.3* ND 6.4 21 FL 1990-94 Stranding Wood & Van Vleet, 1996 T. truncatus liver 0.2* ND 1.7 29 FL 1990-94 Stranding Wood & Van Vleet, 1996 T. truncatus muscle ND ND ND 21 FL 1990-94 Stranding Wood & Van Vleet, 1996 
Lead (Pb) 

Species Tissue 

Mean 

ug/g Min. Max. n Location 

Date 

Sampled Event Reference 

E. robustus bone 50*k NR NR 2l Mexico (Ojo de Liebre Lagoon) 1999 Stranding De Luna & Ros

Hoz, 2004 

E. robustus bone 20*k NR NR 3g Mexico (Ojo de Liebre Lagoon) 1999 Stranding De Luna & Ros

Hoz, 2004 

E. robustus bone 30*k NR NR 3m Mexico (Ojo de Liebre Lagoon) 1999 Stranding De Luna & Ros

Hoz, 2004 

E. robustus epidermis 15*k NR NR 8 Mexico (Ojo de Liebre Lagoon) 1999 Stranding De Luna & Ros

Hoz, 2004 

E. robustus kidney 30*k NR NR 2l Mexico (Ojo de Liebre Lagoon) 1999 Stranding De Luna & Ros

Hoz, 2004 

E. robustus muscle 15*k NR NR 2l Mexico (Ojo de Liebre Lagoon) 1999 Stranding De Luna & Ros

Hoz, 2004 

E. robustus muscle 22*k NR NR 3g Mexico (Ojo de Liebre Lagoon) 1999 Stranding De Luna & Ros

Hoz, 2004 

E. robustus muscle 18*k NR NR 3m Mexico (Ojo de Liebre Lagoon) 1999 Stranding De Luna & Ros

Hoz, 2004 

E. robustus blubber 1.06* 0.33 1.78 5g

Mexico (Sinaloa & Baja California Sur) 1999 Stranding Mendez et al., 2

E. robustus heart 2.31* 1.28 3.4 7g

Mexico (Sinaloa & Baja California Sur) 1999 Stranding Mendez et al., 2

E. robustus kidney 2.09* 0.34 6.12 5g

Mexico (Sinaloa & Baja California Sur) 1999 Stranding Mendez et al., 2

E. robustus liver 2.06* 0.78 3.62 5g

Mexico (Sinaloa & Baja California Sur) 1999 Stranding Mendez et al., 2

E. robustus lung 1.21* 0.36 4.40 7g

Mexico (Sinaloa & Baja California Sur) 1999 Stranding Mendez et al., 2

E. robustus muscle 1.11* 0.42 1.8 5g

Mexico (Sinaloa & Baja California Sur) 1999 Stranding Mendez et al., 2

E. robustus kidney 0.6* 0.3j NR 4 Mexico (Gulf of California) 1999 Stranding 

Ruelas-Inzunza Paez-Osuna, 2

E. robustus liver 0.9* 0.8j 0.9 4 Mexico (Gulf of California) 1999 Stranding 

Ruelas-Inzunza Paez-Osuna, 2

E. robustus muscle 0.6* 0.4j NR 4 Mexico (Gulf of California) 1999 Stranding 

Ruelas-Inzunza Paez-Osuna, 2
Lead (Pb) (continued) 

Species Tissue 

Mean 

ug/g Min. Max. n Location 

Date 

Sampled Event Reference 

E. robustus brain 0.014 0.003h NR 6g Russia (NW Bering Sea) 1994 

Subsistence harvest Tilbury et al., 20

E. robustus kidney 0.028 0.005h NR 6g Russia (NW Bering Sea) 1994 

Subsistence harvest Tilbury et al., 20

E. robustus liver 0.06 0.013h NR 5g Russia (NW Bering Sea) 1994 

Subsistence harvest Tilbury et al., 20

E. robustus brain 0.06 0.06 0.06 1 CA, WA & AK 1988-91 Stranding Varanasi et al., E. robustus kidney 0.053 ND 0.10 10 CA, WA & AK 1988-91 Stranding Varanasi et al., E. robustus liver 0.12 0.02 0.27 10 CA, WA & AK 1988-91 Stranding Varanasi et al., T. truncatus liver <0.10 NR NR 34 SC NR Stranding Beck et al., 199T. truncatus liver 0.45 0.08 1.47 5o TX & AL (Gulf of Mexico) 1990 Stranding 

Kuehl & Haeble1995 

T. truncatus liver 0.26 0.04 0.88 5g TX & AL (Gulf of Mexico) 1990 Stranding 

Kuehl & Haeble1995 

T. truncatus liver 0.68 0.2 2.12 9p TX & AL (Gulf of Mexico) 1990 Stranding 

Kuehl & Haeble1995 

T. truncatus liver 0.48 0.09 1.20 5q TX & AL (Gulf of Mexico) 1990 Stranding 

Kuehl & Haeble1995 

T. truncatus kidney 0.17* ND 1.6 

30 (11 

ND) TX 1991-92 Stranding Meador et al., 1

T. truncatus kidney 0.08* ND 0.14 

13 (11 

ND) FL 1991-92 Stranding Meador et al., 1

T. truncatus liver 0.3* ND 2.6 

30 (11 

ND) TX 1991-92 Stranding Meador et al., 1

T. truncatus liver 0.09* ND 0.2 

13 (10 

ND) FL 1991-92 Stranding Meador et al., 1

M. angustirostris blood 0.13n 0.071n 0.21n 4o CA 1994-95 

live animal collection Owen & Flegal, 
Tin (Sn) 

Species Tissue Mean ug/g Min. Max. n Location 

Date 

Sampled Eve

E. robustus kidney 0.04r ND 0.05 7 CA, WA & AK 1988-91 StranE. robustus liver 0.04r ND 0.04 7 CA, WA & AK 1988-91 StranK. breviceps kidney 0.062e 0.059 0.065 2 FL 1989-94 StranK. breviceps liver 0.39e 0.35 0.41 3 FL 1989-94 StranK. breviceps muscle 0.021e 0.016 0.026 2 FL 1989-94 StranS. bredanensis kidney 0.053r 0.01 0.14 15 

FL (Gulf of Mexico) 1997 Stran

S. bredanensis liver 5.4r 3.8 7.3 15 

FL (Gulf of Mexico) 1997 Stran

T. truncatus blubber 0.63e 0.63 0.63 1 FL 1989-94 StranT. truncatus brain 0.11e 0.11 0.11 1 FL 1989-94 StranT. truncatus heart 0.05e 0.05 0.05 1 FL 1989-94 StranT. truncatus kidney 0.20e 0.025 0.67 16 FL 1989-94 StranT. truncatus liver 1.4e 0.11 11.34 17 FL 1989-94 StranT. truncatus melon 0.19e 0.19 0.19 1 FL 1989-94 StranT. truncatus muscle 0.041e 0.013 0.11 11 FL 1989-94 StranM. augustirostris liver 0.08e 0.06 0.099 2f CA 1991-94 StranP. vitulina liver 0.034e 0.002 0.091 6f CA 1991-97 StranZ. californianus liver 0.045e 0.024 0.087 10f CA 1991-97 StranAbbreviations: ND, the analyte was not detected above the limit of detection; NR, not reported *dry weight aTotal Hg bOrganic (i.e., methyl) Hg cMean ratios of dry to wet weight were 0.26 and 0.22 for TX liver and kidney, respectively (n=31), and 0.29 (n=14) and 0.23 (n=13) for FL liver and kidndMeans for analytes with data below detection limits (ND) were determined with maximum likelihood method for censored data. Means with no ND valu

procedure of Gilbert (1987) for lognormally-distributed data. 

eSum of butyltins, including mono-, di- and tri-butyltin fData for individual animals and organotins given in cited 

source. 

gJuveniles 
hStandard error of the mean 

iFor values below the limit of detection (LOD), one-half the LOD was used to calculate the 

mean 

jStandard deviation kValue extrapolated from graph lCalves mAdults (both sexes) nug/dl osucklings (live, for Owen & Flegal, 1998; stranded, for Kuehl & Haebler, 

1995) 

pAdult males qAdult females rTotal Sn 
Euthanasia Questionnaire Response Summary

Responder Species Stranding 

Type*

Frequency (or #) of Euthanasiain past year

Euthanasia Agent & Route

Induction Agent & Route

Adverse Reactions? 

Disposal Methods

Comments

MarMamCenter, CA Zalophus californianus

Mirounga angustirostrusPhoca vitulina

I 96/796 pentobarb IV, IC tiletamine/zolaz

epam IM

No Renderer no disposal p

HBOI, FL Tursiops truncatus

Kogia brevicepsKogia simus

I 4 pentobarb +- 

phenytoin IC, IP

--- No Beach burial

Landfill

no disposal p

Nat'l Aquarium, MD Phoca vitulina

Pagophilus groenlandicusTursiops truncatusPhocoena phocoena

I 1 in 2003

avg. 1.9/yr (11 yrs)

pentobarb.+ phenytoin

tiletamine/zolazepam diazepam

Yes - lack of sedation

not indicated generally no

C. Harms, NCSU Tursiops truncatus

Kogia brevicepsKogia simusGrampus griseus

I done 3-4 pentobarb +- 

phenytoin IV, IC

xylazine, acepromazine

Yes - hyperexcitability in G. gri. with xylazine or metomidate

Beach burial (if drugs admin.)disposal at sea (no drugs)

no disposal p

W. McFee, NOS, SC Kogia breviceps

Kogia simusZiphius cavirostris

I, P ~60% 1 in past yr. pentobarb IV, IC --- Yes - excitability in 

K. bre.

Burial no disposal p

Mote Mar Lab, FL Tursiops truncatus

Kogia brevicepsKogia simusGlobicephala macrorhynchusLagenodelphis hosei

I, M (Kogia & Glob.)

1-3/yr. pentobarb. IV xylazine No not indicated Disposal pro

elaborate

Cape Cod SN, MA Lagenorhynchus acutus

Phocoena phocoenaDelphinus delphisGlobicephala melas

I, M 179/403 over 5 yr 

period

pentobarb.+- phenytoin

--- Yes - 

hyperexcitability in cetaceans (T. tru., L. acu., D. del., G. mel.) 

truck off Cape to landfilltow to sea & sink

Disposal verrendering sewon't acceptwhale remaicontaminant

VA Marine Sc. Museum, VA

Phoca vitulinaDelphinus delphisKogia breviceps

I 7 in 2003 pentob. +- 

phenytoin

xylazinediazepam

Yes, Observed violent death throes in D. delphis w/ or w/o induction agent, and appeared to have violent rx to acepromazinealso, slight excitability in Grampus w/ xylazine 

commercial carcass dispo. co. to transport to landfillburiallandfill

Difficulty pro
Euthanasia Questionnaire Response Summary

Responder Species Stranding 

Type*

Frequency (or #) of Euthanasiain past year

Euthanasia Agent & Route

Induction Agent & Route

Adverse Reactions? 

Disposal Methods

Comments

Litz, NOAA Fisheries SER, Southeast US, PR & Virgin Is

Tursiops truncatusKogia spp.Steno bredanensisGlobicephala spp.

I, P, M 68/474 from 1995-

2000 (may be moredo not keep these stats.)

pentobarb. IV, IC --- --- landfill Disposal ver

mass strandcetaceans

George, GA DNR Feresa attenuata

Kogia breviceps

5 Kogia breviceps (3 adults/2 calves) 1 Feresa attenuata in 2004

Euthasol (390mg/mL)Gunshot

Xylazine (100mg/mL)

Yes- "Convulsions" prior to death seen with xylazine alone

left on beachburied on sitelandfill

Disposal in rremoval of thpossible prebarbituates frelay toxicos

*I = individualsP = pairsM = mass
THIS PAGE INTENTIONALLY LEFT BLANK 
APPENDIX K 

PRESCOTT GRANT PROGRAM

Prescott Overview FY01-09

Running T

Year Applications Awards Amount Awards A

2001-2002 84 68 $5,781,494 68 $5,

2003 53 48 $4,465,343 116 $102004 35 31 $2,663,983 147 $122005 97 40 $3,620,154 187 $162006 74 42 $3,654,271 229 $202007 80 41 $3,689,886.30 270 $23

2008 75 39 $3,504,647.00 309 $27

2009 84 2009 funding has not been awarded (t
YEAR STATE APPLICANT TITLE

2002

AK Alaska Sealife Center Alaska Sealife Center Rescue and Rehabilitation 

Program

2002

AK Aleut Community of St Paul Island Assessment of northern fur seal entanglement in m

debris on the Pribilof Islands

2002

AK Seward Association for the 

Advancement of Marine Science

Improved rehabilitation techniques through monitonutrition and growth rates in free-ranging and rehabilitated harbor seal pups

2002

AK University of Alaska Anchorage Cellular and subcellular structure of the adrenal m

of the Atlantic bottlenose dolphin (Tursiops Ttruncain relation to physiological stress.

2002

AK University of Alaska Fairbanks Marine mammal tissue and specimen archives - 

University of Alaska Museum

2002 AL Spring Hill College Enhancement of Data Collection 

2002

CA California Department of Fish and 

Game

Marine mammal pathology service for the central California coast

2002

CA Marine Animal Rescue Rehabilitation 

and Release

Diagnostic and Surgery Center (at the Marine MamCare Center at Fort MacArthur)

2002

CA Marine Mammal Center Advancement of clinical care of stranded marine 

mammals at the Marine Mammal Center

2002

CA Marine Mammal Center Development of a biomonitoring program to detect 

diseases and changes in prevalence of known disein pinnipeds stranded along the central California c

2002

CA Northcoast Marine Mammal Center Obtain operating funds to improve rehabilitation fa

and provide more advanced and comprehensive diagnostic abilities. 

2002

CA Regents of the University of 

California/UCSC Stranding Network

UCSC Long Marine Lab Stranding Network upgradInformation Management Systems and capabilities improve or allow access to the National Database.

2002

CA San Jose State Univ. Foundation Movements, Dive Behavior and Survival of Post 

Release CA Sea Lions after Rehabilitation for DomAcid Toxicity

2002

CA San Jose State Univ. Foundation Gray whale and other large whale stranding 

investigations: A collaboration of marine mammal stranding participants in central California

2002

CA Sea World, San Diego Improved care and monitoring of beached marine 

mammals in Southern California

2002

CT Mystic Aquarium Marine mammal stranding program support for My

Aquarium
YEAR STATE APPLICANT TITLE

2002

CT Mystic Aquarium/Sea Research 

Foundation

Prognostic indicators for rehabilitation and survivastranded harp and hooded seals

2002

DE DE Dep't. of Natural Resources and 

Environmental Conservation Renovation of a Seal Holding Facility

2002

FL Clearwater Marine Aquarium Transportation, rehabilitation facilities, and technol

for marine mammal stranding events

2002

FL Dynamac Corporation Marine mammal rescue and stranding program on 

Florida's space coast 

2002

FL Florida Fish and Wildlife Conservation 

Commission

Development of standardized protocols for strandinetworks in Florida

2002

FL Florida Keys Marine Mammal Rescue 

Team

South Florida cetacean rescue triage and necropsfacility and response enhancement project

2002

FL Gulf World Inc To upgrade the quality of Gulf World Marine Park's 

existing stranding facility, improve response time acapabilities. 

2002

FL Harbor Branch Oceanographic 

Institution Marine Mammal Necropsy Facility Ehancement

2002

FL Hubbs-SeaWorld Research Institute Life history and stranding patterns of pygmy and d

sperm whales (genus Kogia) as critical tools in interpreting health assessment trends in wild populations

2002

FL Hubbs-SeaWorld Research Institute Comprehensive stranding enhancement along the 

central east coast of Florida

2002

FL Marine Animal Rescue Society Upgrade MARS from a Short-Term Critical Care F

to a Long-Term Rehabilitation Center

2002

FL Mote Marine Laboratory Mortality Patterns of Cetaceans Stranded on the C

West Coast of Florida

2002

FL Mote Marine Laboratory Facility, staff and equipment upgrades for the dolp

and whale hospital

2002

FL SeaWorld (Orlando) Enhancement of live stranding response capabilitie

and necropsy of code 2 animals in Northeast and ecentral Florida: SeaWorld Florida equipment upgra

2002

FL University of Florida, College of 

Veterinary Medicine

Marine Mammal Microbiology Diagnostic and SuppLaboratory

2002

GA Georgia Depart. Natural Resources Implement Marine Mammal Stranding Network in 

Georgia

2002

HI Hawaiian Islands Stranding Response 

Group

Cooperative partnerships in Hawaii which upgrade capacity of the region's stranding ntework, detect, dtermine the cause of marine mammal morbidity/mortalities
YEAR STATE APPLICANT TITLE

2002

HI Robert C. Braun Incidence of disease and health evaluation of Haw

Monk Seals (Monachus schauinslandi)in the Main Hawaiian Islands

2002

MA Cape Cod Stranding Network Enhanced mass stranding response on Cape Cod

Success through preparation, protocols and coope

2002

MA Cape Cod Stranding Network Health assessment of stranded marine mammals: 

Interpretation and field applications of blood and tianalyses

2002

MA New England Aquarium Corporation Marine Mammal Stranding Response, Rescue and 

Rehabilitation at the New England Aquarium in Suof the National Marine Fisheries Service under the Marine Protection Act

2002

MA New England Aquarium Corporation An Analysis of the Spacial Patterns and Genetic 

Characteristics of the Harp and Hooded Seals AloUnited States Eastern Coast

2002

MA Whale Center of New England A Program to Respond to Stranded Marine Mamm

Northeastern Massachusetts-Evaluation, Rescue, Collection, and Public Education

2002

MA Woods Hole Oceanographic Institution Necropsy enhancement for stranded marine mamm

on Cape Cod

2002 MD Maryland Depart Natural Resources Marine Mammal Stranding Response in Maryland 

2002

MD National Aquarium in Baltimore Enhanced Operations: Hospital pool restoration an

satellite tags. Marine animal rescue program of the National Aquarium in Baltimore

2002

MD National Aquarium in Baltimore Stranded Marine Animal Education and Outreach f

professionals and the Public Marine Animal RescuProgram of the National Aquarium in Baltimore

2002

ME College of the Atlantic Enhancement of the marine mammal stranding 

response and rescue program for the Maine coastregion, Rockland (ME) east, by creation of a new personnel position, network expansion, equipment upgrades, and acquisitions, and facility improveme

2002

ME College of the Atlantic Use of stable isotope analysis to determine individ

population and ecosystem health of Gulf of Maine Balaenopterids

2002

ME Marine Animal Lifeline Enhancing seal rehabilitation care through improve

isolation and the implementation of dedicated areaveterinary treatments and necropsy
YEAR STATE APPLICANT TITLE

2002

ME Marine Animal Lifeline Development and use of a Geographic Information 

System for analysis of harp, hooded and harbor sesightings/stranding locations: Adding a spatial dimension to strandings

2002

MS Institute for Marine Mammal 

Studies/Marine Life Oceanarium

Enhancement and Refurbishment of a Pre-Existing Stranding Facility and Development of First RespoCapability Including Equipment and Training for MMammal Live Response

2002

NC University of North Carolina, Wilmington Enhanced evaluation of human interaction with 

bottlenose dolphins (Tursiops truncatus ) in North 

Carolina and Virginia

2002

NC University of North Carolina, Wilmington Enhance tissue collection and health monitoring of 

stranded of marine mammals in NC

2002

NJ Marine Mammal Stranding Center To provide safe water and land transport of marine 

mammals

2002

NJ Marine Mammal Stranding Center Operational expenses to support and enhance ma

mammal and sea turtle rehabilitation

2002

NY Riverhead Foundation for Marine 

Research and Preservation

Request for operational support to upgrade facilitiethe New York State Marine Mammal and Sea TurtStranding Program

2002

NY Riverhead Foundation for Marine 

Research and Preservation

Characterization of ice seal movements and evaluof existing treatment protocols employed in the rehabilitation and field assessment through the usesatellite telemetry and video documentation of strapinnipeds

2002

OK Oklahoma State University A comprehensive two-year study of the viral, bacte

mycologic and toxicologic conditions associated wmarine mammal strandings in the Gulf coast of the 

2002

OR Oregon State University Enhancing the capabilities of the Oregon Marine 

Mammal Stranding Network

2002

PA Trustees of the University of 

Pennsylvania

Toxicological and Pathoanatomic Stranding responand post-mortem evaluation of stranded marine mammals in San Juan Couny Washington

2002

TX Texas Marine Mammal Stranding 

Network

Improved recovery and rehabilitation of stranded mmammals

2002

TX Texas Marine Mammal Stranding 

Network

Improved data collection from living and dead marmammal strandings

2002

VA Virginia Marine Science Museum Improving Triage and Treatment of Live Stranded 

Marine Mammals in Virginia
YEAR STATE APPLICANT TITLE

2002

VA Virginia Marine Science Museum Improving response to and assessments of dead 

marine mammal stranding in Virginia

2002

WA Cascadia Research Collective Trends, spatial distribution, health effects of 

contaminants in Washington harbor seals from straanimals

2002

WA Cascadia Research Collective Strandings of large whales in Washington state an

examination of contaminant accumulation

2002

WA WA Depart. Fish and Wildlife Investigation of health parameters and causes of 

mortality in marine mammals from Washington wa

2002

WA Whale Museum Stranding response and post-mortem evaluation o

stranded marine mammals in San Juan Couny Washington

2002

WA Wolf Hollow Wildlife Rehabilitation 

Center

Enhancement and Support of Marine Mammal Treatment Facility

2002

WA Wolf Hollow Wildlife Rehabilitation 

Center

Upgrade of Life Support System for Marine MammHolding Pools

2003

AK University of AK Anchorage The effects of acute and chronic stress on the Atla

bottlenose dolphin (Tursiops Truncatus) Adrenal g

2003

CA City of Malibu Consistency and improvement in marine mammal 

stranding response for the City of Malibu coastline

2003

CA Friends of the Seal Lion Marine 

Mammal Center

Pathology enhancement and database developme

2003

CA Marine Mammal Care Center Veterinary Fellowship Program at the Marine Mam

Care Center at Fort MacArthur

2003

CA Marine Mammal Center Continuation of a biomonitoring program to detect 

diseases and changes in prevalence of know diseain pinnipeds stranded along the central California c

2003

CA Marine Mammal Center Advancement of clinical care of stranded marine 

mammals, especially those intoxicated with the algtoxin domoic acid

2003

CA Natural History Museum of Los Angeles 

County

Development of an Improved Protocol for ExaminiStranded Cetaceans: Combining Museum-based Science and Veterinary Medicine

2003

CA Regents of the University of CA Cancer in stranded CA sea lions: answering quest

about the role of contaminants, genetics, and diagof herpes virus infection and early cancers
YEAR STATE APPLICANT TITLE

2003

CA Regents of the University of CA Enhancement of Stranding Response at the Unive

of CA Santa Cruz Long Marine Lab

2003

CA San Jose State University Foundation Improving the Response to Marine Mammal Stran

by Moss Landing Marine Laboratories in Central C

2003

CA Santa Barbara Museum of Natural 

History

Enhancement of Facility, Equipment and Supplies Recover and Archive Dead, Stranded Cetaceans

2003

CA Sea World, San Diego Improving response, care and diagnostic for strand

marine mammal in Southern CA

2003

CA Sea World, San Diego Enhancement and integration of southern CA stran

marine mammal post-mortem evaluations and matarchives

2003

CT Mystic Aquarium Support for the Marine Mammal Stranding Program 

Mystic Aquarium

2003

CT Mystic Aquarium Application and refinement of a prognostic index to 

evaluate the health, nutritional status, and cause ostranding of stranded harp seals and hooded seals the Northeastern U.S., with particular emphasis on disease with epizootic potential

2003

CT University of Connecticut Evaluation of immune functions are potential diagn

and prognostic tools in stranded marine mammals

2003

DC Smithsonian Institution Enhancement and Maintenance of the Smithsonia

Institution's Cetacean Distributional Database and Research Collection's (1 Year)

2003

DE Delaware DNR Outfitting a necropsy lab to improve acquisition, an

and storage of levels A, B and C data from strandemarine mammals in coastal Delaware and it's inlanwaterways

2003

FL FL Fish & Wildlife Conservation 

Commission

Facilities of Southwest Florida Cetaceans Rescue Recovery

2003

FL Gulf World, Inc. Request for equipment to help facilities large anim

and to make moving of all animals easier, safer anfaster and for financial assistance with stranding faoperations

2003

FL Hubbs-Sea World Research Institute Enhancing live animal stranding response, necrop

procedures and tissue archiving capabilities along central and northeast coast of FL
YEAR STATE APPLICANT TITLE

2003

FL Marine Animal Rescue Society (MARS) Improve MARS' impact on live stranding events in 

FL, while nurturing existing outreach channels with better presence

2003 FL Mote Marine Lab Facility expansion for the Dolphin and Whale Hosp2003 FL University of Florida Poxvirus Infections in North American Pinnipeds 2003

LA Audubon Nature Institute, Inc. Enhancement of data collection from stranded ma

mammals by the Louisiana Marine Mammal RescuProgram

2003

MA Cape Cod Stranding Network, Inc. Enhanced stranding response and investigation on 

Cape Cod: assessment, data, collection, samplingdisposal

2003

MA New England Aquarium Corporation Improved field diagnostic and post release monitor

mass stranded cetaceans

2003

MA New England Aquarium Corporation Improving marine mammal stranding response and 

rehabilitation in Massachusetts, New Hampshire, aSouthern Maine

2003

MA Woods Hole Oceanographic Institution 2003 Necropsy Enhancement for Stranded Marine 

Mammals

2003

MD Maryland DNR Improving Response to and Assessment of Dead 

Stranded Marine Mammals in Maryland

2003

MD National Aquarium in Baltimore Enhanced operations of Marine Animal Stranding 

Rescue and Rehabilitation through the procurememedical/rescue equipment and a centralized storafacility.

2003

ME College of the Atlantic A medium-range response vessel to enhance the 

Marine Mammal Stranding Response Program (MMSRP) for Mid-coast/Downeast Maine

2003

ME Marine Animal Lifeline Improved veterinary care and marine mammal 

rehabilitation program support

2003

ME Marine Animal Lifeline Enhancing and supporting marine mammal rescue 

response and stabilization procedures

2003

ME University of Southern Maine Establishing a national resource of marine mamma

lines for toxicological, infectious disease, and othebiomedical research

2003

MS Institute for Marine Mammal Studies, 

Inc.

Evaluation of trends and possible causes of marinmammal strandings in the Mississippi sound and adjacent waters

2003

NC University of North Carolina, Wilmington Enhancing response to and necropsy of stranded 

whales in North Carolina and Virginia
YEAR STATE APPLICANT TITLE

2003

NC University of North Carolina, Wilmington Enhanced tissue collection and health monitoring o

stranded marine mammal's in North Carolina and Virginia

2003

NJ Marine Mammal Stranding Center 

(MMSC)

To ensure and support MMSC staffing requiremen

2003 NY Mount Sinai School of Medicine Atlas of mysticete anatomy 2003

NY Riverhead Foundation for Marine 

Research and Preservation

Facility upgrade to enhance access to veterinary cfor marine mammals while collecting valuable supplemental data

2003

OR Oregon State University Enhancing the capabilities of the Oregon marine 

mammal stranding network

2003

SC South Carolina DNR Continuation of South Carolina's Marine Mammal 

Strandings Network

2003

TX Texas Marine Mammal Stranding 

Network (TMMSN)

Improved Recovery and Treatment of Live StrandeAnimals--Rescue, Rehabilitation and Release

2003

TX Texas Marine Mammal Stranding 

Network (TMMSN)

Improved data collection from living and dead marmammal strandings

2003

VA Virginia Marine Science Museum Supporting response to dead marine mammal 

strandings in Virginia

2003

WA Washington Department of Fish & 

Wildlife

Investigations of marine mammals health parametand causes of mortality in marine mammals from Washington waters

2003

WA Whale Museum Stranding response and post-mortem evaluation o

stranded marine mammals in San Juan County, Washington

2004

AK Aleut Community of St Paul Island Assessment of northern fur seal entanglement in m

debris on the Pribilof Islands.

2004

AK Seward Association for the 

Advancement of Marine Science

Rescue and Rehabilitation of Pinnipeds and Cetacin AK

2004

AK University of AK Fairbanks Morbidity and mortality of marine mammals on the 

coast of Alaska Peninsula

2004 AL Marterra Foundation, Inc. Enhancement of data collection Phase 2 2004

CA Marine Mammal Care Center Enhanced Veterinary Medical Program at the Mari

Mammal Care Center at Fort MacArthur

2004

CA Northcoast Marine Mammal Center Enhance diagnostic and treatment abilities, improv

facilities for stranded marine mammals; continue employment of facility manager and primary investigating veterinarian to accomplish goals and objectives

2004 CA Regents of the University of CA Marine Mammal Pathology for the Central CA 
YEAR STATE APPLICANT TITLE

2004

CA San Jose State University Foundation Movements, Dive Behavior and Survival of Post 

Release CA Sea Lions after Rehabilitation for DomAcid Toxicity

2004

CA Santa Barbara Marine Mammal Center Pinniped Rescue Capture Techniques Training Pro

2004

DC Smithsonian Institution Enhancement and Maintenance of the Smithsonia

Institution's Cetacean Distributional Database and Research Collection's (Year 2)

2004

FL Dynamac Corporation Marine Mammal Stranding Program on Florida's S

Coast: Upgrade Rescue and Data Collection

2004

FL Harbor Branch Oceanographic 

Institution

Diagnostic Equipment Purchase 

2004

FL Harbor Branch Oceanographic 

Institution

Stranding Center Pool Enhancement 

2004

FL Hubbs-Sea World Research Institute Cetacean stranding response and the developmen

photographic stranding atlas for network education training

2004

FL Marine Animal Rescue Society (MARS) Improve MARS' impact on live stranding events in 

FL, while nurturing existing outreach channels with better presence (2nd Year Funding)

2004

FL Mote Marine Laboratory Enhancement of marine mammal rescue and stran

program for central west FL

2004

HI Hawaiian Islands Stranding Response 

Group

Collect consistent level A data throughout the jurisdiction, including remote areas, and collect levand C data from stranding of dead marine mamma

2004

HI Hawaiian Islands Stranding Response 

Group

Collect consistent level A data throughout the jurisdiction, including remote areas, and collect levand C data from stranding of dead marine mamma(2nd Year Funding)

2004

LA Audubon Nature Institute, Inc. Enhancement of data collection from stranded ma

mammals by the Louisiana Marine Mammal RescuProgram

2004

MA Cape Cod Stranding Network, Inc. The science of stranding response: supporting dat

collection from live and dead stranded marine mamon Cape Cod

2004

MA Whale Center of New England A project to increase the breadth and efficiency of 

marine mammal stranding response on MassachuNorth Shore
YEAR STATE APPLICANT TITLE

2004

MD National Aquarium in Baltimore Enhanced operations of Marine Animal Stranding 

Rescue and Rehabilitation through the procurememedical/rescue equipment (2nd Year Funding)

2004

ME College of the Atlantic Enhancement of the Marine Mammal Stranding 

Response Program (MMSRP) for the Midcoast/Downeast Maine

2004

NC North Carolina State University Improving live marine mammal stranding response 

North Carolina through rapid diagnostic capability short-term holding capacity

2004

NJ Marine Mammal Stranding Center 

(MMSC)

To ensure and support MMSC staffing requiremen(2nd Year Funding)

2004

NY Riverhead Foundation for Marine 

Research and Preservation

Evaluation of current rescue response protocols anpost-rehabilitation monitoring of marine mammals through the enhancement of data collection, satelland radio tracking, and data on the prevalence of morbilli and herpes in pinnipeds in the northwest 

2004

VA Virginia Marine Science Museum Recovery and treatment of Live Stranded Marine 

Mammals in Virginia

2004

WA

Cascadia Research Collective

Cetacean stranding response in Washington with special attention to gray whales and harbor porpoi

2004

WA Cascadia Research Collective Trends, spatial distribution, health effects of 

contaminants in Washington pinnipeds

2004

WA Whale Museum Stranding response and post-mortem evaluation o

stranded marine mammals in San Juan County, Washington (2nd Year Funding)

2004

WA Wolf Hollow Wildlife Rehabilitation 

Center

Advancement of Marine Mammal Rehabilitation Program, Facilities, Techniques, Training and Res

2005 AK

Seward Association for the Advancement of Marine Science

Alaska Region Stranding Network coordination an

development project 

2005 AK University of Alaska - Fairbanks

Salvaging beach-dead marine mammals - collaboreffort between UAM, volunteer salvage crews and NOAA 

2005 CA

Hubbs-SeaWorld Research Institution (CA)

Post-release monitoring of rehabilitated marine mammals in southern California through the use oand UHF (satellite-linked) radio telemetry 

2005 CA

Marine Mammal Care Center at Fort MacArthur

Support and upgrade of the Veterinary Medical Proat the Marine Mammal Care Center at Fort MacArt
YEAR STATE APPLICANT TITLE

2005 CA Pacific Marine Mammal Center

Enhancing diagnostic applications for stranded mamammals and improving operational capabilities 

2005 CA San Jose State University Foundation

Body burden assessments of total mercury in stranPacific harbor seals, Phoca vitulina richardii , in ce

California 

2005 CA Sea World San Diego

Equipment and personnel for improving response care for live stranded marine mammals in southern California 

2005 CA The Marine Mammal Center

Development of a biomonitoring program to detect diseases and changes in prevalence of known disein pinnipeds stranded along the central California cyear 3 

2005 CA

The Regents of the University of California

Enhancement of stranding response at University California Santa Cruz Long Marine Lab 

2005 CA

The Regents of the University of California

Marine Mammal Pathology Service for the central California coast, Part 3 

2005 CT Mystic Aquarium

Support and enhancement for the Marine MammaStranding Program at Mystic Aquarium 

2005 DC Smithsonian Institution

Enhancement of Level A, B and C Cetacean DataImproving data quality and access to the SmithsonInstitution's Cetacean Distributional Database 

2005 DE

Delaware Department of Natural Resources

Support staffing and operational needs to facilitate improved stranding response for marine mammals occurring along the Delaware coast and its waterw

2005 FL Dynamac Corporation

Marine Mammal Stranding Program on Florida's spcoast 

2005 FL

Florida Fish and Wildlife Conservation Commission - Jacksonville

Equipping the Northeast Florida Stranding Networresponse to cetacean strandings 

2005 FL

Harbor Branch Oceanographic Institution

Research project on cardiomyopathy of dwarf and pygmy sperm whales 

2005 FL Hubbs-Sea World Research Institute

An evaluation of demographic and health related f

of the Indian River Lagoon dolphin population folloan Unusual Mortality Event 

2005 FL Marine Animal Rescue Society

Improve MARS' impact on live stranding events in Florida, while nurturing existing outreach channels a better presence 

2005 FL Mote Marine Laboratory

Support for operation with the increased capacity oDolphin and Whale Hospital 
YEAR STATE APPLICANT TITLE

2005 FL Mote Marine Laboratory

Enhancement of the marine mammal stranding proand post-release monitoring of rehabilitated cetacefor central west Florida 

2005 HI Robert C. Braun, D.V.M.

Hawaiian monk seal health trend surveillance and captive care response 

2005 LA Audubon Nature Institute, Inc.

Enhancement and maintenance of data collection stranded marine mammals by the Louisiana MarinMammal Rescue Program: Phase 2 

2005 MA Cape Cod Stranding Network

Pursuing excellence in marine mammal stranding response: support for basic operational needs and innovative solutions to stranding challenges 

2005 MA New England Aquarium

Strengthening marine mammal stranding response rehabilitation at the New England Aquarium 

2005 MA The Whale Center of New England

Marine mammal stranding response on Massachunorth shore: Continuation and expansion of data collection and assistance to stranded animals 

2005 MA Woods Hole Oceanographic Institution

Development of necropsy, anatomy, and pathology training materials from stranded marine mammals 

2005 MD

Maryland Department of Natural Resources

Enhancing the quality and quantity of data collectiofrom dead stranded marine mammals in Maryland 

2005 ME College of the Atlantic

Maintenance and enhancement of the Marine MamStranding Response Program (MMSRP) for the midcoast/downeast region of Maine, 2005-2006 

2005 ME University of New England

The enhancement of pinniped rehabilitation at MarAnimal Rehabilitation Center 

2005 ME University of Southern Maine

Establishing a national resource of marine mammalines for toxicological, infectious disease, and othebiomedical research 

2005 MS Institute for Marine Mammal Studies

Evaluation of trends and possible causes of Atlantbottlenose dolphin (Tursiops truncatus ) strandings 

the Mississippi Sound and adjacent waters (continstudy) 

2005 NC

University of North Carolina - Wilmington

Enhanced tissue collection and health monitoring ostranded marine mammals in North Carolina and Virginia 

2005 NJ Marine Mammal Stranding Center

To enhance and support basic needs for volunteer training and response, treatment and data collectiolive and dead stranded marine mammals in New J
YEAR STATE APPLICANT TITLE

2005 NY

The Riverhead Foundation for Marine Research

Facility upgrade to enhance operational support anresponse to live marine mammal strandings while collecting valuable supplemental data 

2005 OR Oregon State University

Enhancing the capabilities of the Oregon Marine Mammal Stranding Network 

2005 OR Portland State University

Implementation of an archival system for cetacean tissue and anatomical specimens collected during years of stranding network activity 

2005 TX

Texas Marine Mammal Stranding Network

Response, treatment and data collection from livindead stranded marine mammals 

2005 VA Virginia Aquarium Foundation

Enhancing response to live marine mammal strandin Virginia 

2005 WA

Washington Department of Fish and Wildlife

Investigations of marine mammal health parameteand causes of mortality in Washington state 

2005 WA

Wolf Hollow Wildlife Rehabilitation Center

Advancement of marine mammal rehabilitation 

program, operations, facilities, training and researc

2006 AK Aleut Community of St. Paul Island

Assessment of northern fur seal (Callorhinus ursin

entanglement in marine debris on the Pribilof Islan

2006 AK University of Alaska Fairbanks

Improvements to marine mammal data and specimarchives at UAM 

2006 AK University of Alaska Fairbanks

Morbidity and mortality of marine mammals on the coast of the Alaska Peninsula 

2006 CA City of Malibu

Advancement of marine mammal stranding respon

for the city of Malibu coastline 

2006 CA

Marine Mammal Care Center at Fort MacArthur

Staffing resources upgrade at the Marine Mammal Center at Fort MacArthur 

2006 CA Northcoast Marine Mammal Center

Enhance response, rescue and rehabilitation on Northern California's remote coastline 

2006 CA Pacific Marine Mammal Center Enclosure renovation and pool construction projec

2006 CA Regents of the University of California

Marine Mammmal Pathology Service for the CentrCalifornia Coast, Part 4 

2006 CA Regents of the University of California

Enhancement of Stranding Response at University California Santa Cruz Long Marine Lab 

2006 CA

Santa Barbara Museum of Natural History

Support for and enhancement of data collection froDead-Stranded cetaceans 

2006 CA Sea World San Diego

Personnel for improving stranded animal response Southern California 

2006 CA The Marine Mammal Center

Development of diagnostic assays to detect lungw(Otostrongylus circumlitus) infection in stranded northern elephant and Pacific harbor seals 
YEAR STATE APPLICANT TITLE

2006 CT

Sea Research Foundation, Inc. (Mystic Aquarium)

Support and Enhancement for the Marine MammaStranding Program at Mystic Aquarium 

2006 CT University of Connecticut

Evaluation of immune functions as potential diagnoand prognostic tools in stranded marine mammal, regional approach. 

2006 FL

Florida Fish and Wildlife Conservation Commission

Stranding and Necropsy Training For Increasing Qof Level A, B, and C Data Collection by the Florida Cetacean Stranding Network 

2006 FL Hubbs-SeaWorld Research Institute

Enhancing live animal stranding response, assesscetacean health trends, and evaluating neonatal mortality trends of the bottlenose dolphin (Tursiops truncatus) along the east coast of Florida 

2006 FL Hubbs-SeaWorld Research Institute

Validation of historic marine mammal stranding dafrom the southeastern United States 

2006 FL Marine Animal Rescue Society (MARS)

Improve MARS' mass stranding response capabili(immediate triage and necropsy support) and postrehabilitation monitoring preparedness for the SEUstranding region 

2006 FL Mote Marine Laboratory

Investigating brevetoxin-induced mortality in bottledolphins stranded in central west Florida 

2006 FL Nova Southeastern University

An Analysis of Kogia Stranding Data Collected by Southeast Region Marine Mammal Stranding Netw

2006 FL University of Florida

Clinical Pathology and Histopathologic Processing Analysis of Cetaceans in Northern and Central Flo

2006 GA GA Dept. of Natural Resources Enhance Georgia Marine Mammal Stranding Netw

2006 MA Cape Cod Stranding Network

The Next Step: Operational Support to Enhance Stranding Response Capabilities and Promote DatAnalysis and Publication 

2006 MA New England Aquarium Corporation

Advancement of Clinical Care, Data Collection, an

Pathology Training for Marine Mammal Stranding Response 

2006 MA The Whale Center of New England

Marine mammal stranding response on MassachuNorth Shore: Timely assistance for living animals acomprehensive regional data collection 

2006 MA Woods Hole Oceanographic Institution

2006 Necropsy of Fresh and Human-Impacted MaMammal Strandings in SE Massachusetts and CapCod 
YEAR STATE APPLICANT TITLE

2006 MD National Aquarium in Baltimore

2006 National Aquarium in Baltimore, Marine AnimRescue Program Operations 

2006 ME College of the Atlantic

Maintenance and Enhancement of the Marine MamStranding Response Program (MMSRP) for the Mcoast/Downeast Region of Maine, 2006-2007 

2006 ME Marine Animal Lifeline

Veterinary care staffing and rehabilitation supply expense support for the marine mammal rehabilitaprogram 

2006 ME University of New England

The Enhancement of Cetacean Response, Treatmand Data Collection in Southern Maine 

2006 ME University of New England Composting as a Disposal Option 

2006 NC North Carolina State University

Improving live marine mammal stranding response North Carolina through a rapid diagnostic capabilitshort-term holding capacity 

2006 NC University of North Carolina Wilmington

Enhancing response to and necropsy of large whaNorth Carolina, Virginia and South Carolina 

2006 NC University of North Carolina Wilmington

Enhanced tissue collection and health monitoring ostranded marine mammals in North Carolina and Virginia 

2006 NJ Marine Mammal Stranding Center

To enhance and support Marine Mammal StrandinCenter staffing requirements 

2006 NY

Riverhead Foundation for Marine Research and Preservation

Facility Upgrade to Enhance Operational Support Response to Marine Mammal Strandings 

2006 OR Oregon State University

Enhancing the capabilities of the Oregon Marine Mammal Stranding Network 

2006 TX

Texas Marine Mammal Stranding Network

Response, treatment and data collection from livindead stranded marine mammals 

2006 VA

Virginia Aquarium and Marine Science Center Foundation 

Continuing Investigation of Dead Marine Mammal Strandings in Virginia 

2006 WA Orca Network

Stranding response and post-mortem examination stranded marine mammals in Central Puget SoundWashington 

2006 WA

Washington Department of Fish and Wildlife

Response to stranded marine mammals and investigating causes of mortality in Washington wa

2006 WA

Wolf Hollow Wildlife Rehabilitation Center

Care of Live Stranded Harbor Seals in the NorthweRegion: Treatment, Data Management, Research, Training 
YEAR STATE APPLICANT TITLE

2007 AK Alaska Department of Fish and Game Reduce Entanglements of Live Stranded Steller Sea 

Alaska

2007 AK Seward Association for the Advancement of Marine 

Science

Basic operations and medical care of rehabilitation pa

2007 AK Seward Association for the Advancement of Marine 

Science

Alaska Region Stranding Network Development and T

2007 AK University of Alaska Fairbanks Improvements to marine mammal data and specimen 

at UAM.

2007 AK Alaska Whale Foundation Improving Alaska Whale Foundation's disentangleme

preparedness in Southeast Alaska

2007 CA Northcoast Marine Mammal Center Enhance response, rehabilitation and data collection 

stranded marine mammals on Northern California's recoastline

2007 CA The Marine Mammal Center Stranded harbor seals as indicators of pathogen prev

harbor seals of San Francisco, a heavily urbanized environment

2007 CA The Marine Mammal Center Understanding the cyclic dynamics of leptospirosis in 

sea lions (Zalophus californianu

s )

2007 CA The Regents of the University of California Continued Prescott Program Enhancement of Strand

Response at University of California Santa Cruz Long Lab

2007 CA The Regents of the University of California Marine Mammal Pathology Service for the Central Ca

Coast, Part 5

2007 CA San Jose State University Foundation Enhancing the Response to Marine Mammal Strandin

Moss Landing Marine Laboratories in Central Californ

2007 CA Santa Barbara Museum of Natural History Enhancement of Cetacean Bio-Monitoring in Central 

Southern California

2007 CA Marine Mammal Care Center at Fort MacArthur Improving operational capabilities at the Marine Mam

Center at Fort MacArthur

2007 CA Friends of the Sea Lion, Inc. dba Pacific Marine 

Mammal Center

Diagnostic and Treatment Enhancements for StrandeMammals

2007 CA Biomimetica Establishing Auditory Evoked Potential Measurement 

Capabilities for Stranding Response Teams
YEAR STATE APPLICANT TITLE

2007 CT Mystic Aquarium Support and Enhancement for the Marine Mammal S

Program at Mystic Aquarium

2007 DE DNREC - Delaware Division of Fish and Wildlife Support staffing and operational needs for comprehen

stranding response and health assessments for marinmammals stranding in Delaware

2007 FL Hubbs-SeaWorld Research Institute Enhancing live animal response, public outreach and 

education, and improving the assessment of ceteceatrends and interactions between bottlenose dolphins arecreational fishing gear

2007 FL Hubbs-SeaWorld Research Institute Age, growth, reproduction and feeding ecology of rou

toothed dolphins from single and mass strandings in with a compilation of voucher materials deposited in vinstitutions

2007 FL Florida Fish and Wildlife Conservation Commission Cetacean Stranding Response and Training in Lee an

Counties, Florida

2007 FL Mote Marine Laboratory, Inc. Support for Operation of the Dolphin and Whale Hosp2007 HI Attractions Hawaii , dba Sea Life Park by Dolphin 

Discovery

Development of live cetacean stranding response teamain Hawaiian Islands and a long-term cetacean rehafacility on Oahu, Hawaii

2007 HI Hawaii Pacific University Continuing To Enhance Cetacean Necropsy Capabili

Main Hawaiian Islands

2007 MA Cape Cod Stranding Network, Inc. Maintaining Readiness: Operational Support for Sing

Mass Stranding Response and Training on Cape Cod Southeastern Massachusetts

2007 MA New England Aquarium Corporation Enhancement of Marine Mammal Response, Rehabil

and Data Collection with a Focus on Mass Stranding 

2007 MD Maryland Department of Natural Resources Continuation of Enhanced Level B and C Data Collec

Dead Stranded Marine Mammals in Maryland

2007 ME College of the Atlantic Maintenance and enhancement of the Marine Mamm

Stranding Response Program (MMSRP) for the Mid-cDowneast region of Maine, 2007-2008

2007 ME Maine Department of Marine Resources Support basic needs of organizations for response, tr

and data collection from living and dead stranded mamammals.
YEAR STATE APPLICANT TITLE

2007 ME University of New England Marine Animal Rehabilitation Center Diagnostic Enha

Disease Surveillance, and Operational Support

2007 MP Northern Marianas College Building the capacity of US Insular areas for Marine M

Stranding Response

2007 NC University of North Carolina Wilmington Enhanced tissue collection and health monitoring of s

marine mammals in North Caorlina and Virginia

2007 NJ Marine Mammal Stranding Center To enhance and support Marine Mammal Stranding C

staffing and veterinary requirements

2007 NY Riverhead Foundation for Marine Research and 

Preservation

Program Support to Enhance Operations for ResponsTreatment and Data Collection from Living and Dead Marine Mammals

2007 OR Oregon State University Enhancing the Capabilities of the Oregon Marine Mam

Stranding Network

2007 OR Portland State University Diagnostic Assessment of Health and Investigation of 

Relationship of Diet and Exposure to Biotoxins in StraMarine Mammals in Oregon

2007 PR Puerto Rico Department of Natural and 

Environmental Resources

Puerto Rico Marine Mammal Rescue Network 

2007 TX Texas Marine Mammal Stranding Network Response, treatment and data collection from living a

marine mammals stranded along the Texas coast

2007 VA Virginia Aquarium & Marine Science Center 

Foundation, Inc.

Response, rehabilitation & examination of stranded mmammals in Virginia

2007 WA Cascadia Research Collective Stranding response in southern Puget Sound and cen

coast Washington 2007-2009 including large whale sresponse for all Washington

2007 WA Washington Department of Fish and Wildlife Enhanced response to stranded marine mammals an

investigating causes of mortality in Washington water

2007 WA Wolf Hollow Wildlife Rehabilitation Center Care of Live Stranded Harbor Seals in the Northwest 

Treatment, Data Collection and Compilation, and Tra

2008 AK Seward Association for the Advancement of Marine 

Science

Basic Operations and Medical Care of Rehabilitation 

2008 AK Seward Association for the Advancement of Marine 

Science

Alaska Region Stranding Network Annual Meetings aTraining
YEAR STATE APPLICANT TITLE

2008 CA Northcoast Marine Mammal Center Enhanced Stranding Response and Rehabilitation on 

Coast: Support for Basic Operational Needs and Devof Written Protocols and Manuals

2008 CA California Academy of Sciences Improving marine mammal data collection facilities an

specimen archives at the California Academy of Scien

2008 CA Regents of the University of California, Davis Monitoring post-release movement and survival of reh

harbor seal pups

2008 CA Regents of the University of California, Santa Cruz Continued Prescott Program Enhancement of Strand

Response at University of California Santa Cruz Long Lab

2008 CA San Jose State University Foundation A vessel for whale disentanglement in central californ2008 CA Santa Barbara Museum of Natural History Enhancement of Cetacean Bio-Monitoring in Central 

Southern California

2008 CA City of Malibu Marine Mammal Stranding Response and Data Colle

the City of Malibu

2008 CA Marine Mammal Care Center at Fort MacArthur Facility expansion and Upgrade at the Marine Mamm

Center at Fort MacArthur

2008 CT Sea Research Foundation, Inc. Support and Enhancement for the Marine Mammal S

Program at Mystic Aquarium

2008 FL Florida Atlantic University Foundation (Harbor 

Branch Oceanographic Institution)

Furthern Investigations of the Etiopahogenesis of Kog

Cardiom

yopath

y

2008 FL Hubbs-SeaWorld Research Institute Enhancing public and network outreach and educatio

SEUS stranding network and support for marine mamstranding response along the east coast of Florida

2008 FL Marine Animal Rescue Society Enhance MARS' stranding support, facility capacity a

outreach within the network through continual improvproven methods

2008 FL Mote Marine Laboratory Monitoring natural and human-related mortality of cet

along the central West coast of Florida and post-releatracking of rehabilitated animals

2008 FL Mote Marine Laboratory Facility and Equipment Enhancement at the Dolphin a

Whale Hospital

2008 GA GA Department of Natural Resources Enhancing the Georgia Marine Mammal Stranding Ne

Through Improved Academic Collaboration
YEAR STATE APPLICANT TITLE

2008 HI Hawaii Pacific University Continuing to Build Capacity for Cetacean Necropsies 

Main Hawaiian Islands and the Greater Pacific

2008 LA Audubon Nature Institute, Inc. Louisania Marine Mammal Rescue Program: continue

program operations and response for live and dead swhile increasing Level A, B, and C data collection and for analysis

2008 MA New England Aquarium Expanding Our Understanding of Marine Mammal Str

through Enhanced Proficiency of Staff and VolunteersIncreased Sample Collection and Analysis, and More Manipulation of Data

2008 MA Woods Hole Oceanographic Institution 2008- Examination of Offshore Large Whale Mortalitie2008 MD National Aquarium in Baltimore 2008 Support and Enhancement of the National Aqua

Baltimore's Marine Animal Rescue Program

2008 MD Maryland Department of Natural Resources Enhanced Tissue and Data Collection from Dead Stra

Marine Mammals in Maryland

2008 ME College of the Atlantic Maintenance and Enhancement of the Marine Mamm

Stranding Program (MMSRP) for the Mid-Coast/DownRegion of Maine, 2008-2009

2008 ME University of New England Broadening Observations Through Technology, Cont

Infectious Disease Monitoring, and Operational SuppMarine Animal Rehabilitation Center at the University England

2008 ME Maine Department of Marine Resources Prescott Funds for the Maine Department of Marine R

Marine Mammal Response

2008 MS Institute for Marine Mammal Studies, Inc Enhancement of marine mammal stranding response

collection, and tissue analysis in the Mississippi Sounadjacent waters of the North-Central Gulf of Mexico

2008 NC University of North Carolina, Wilmington Enhanced tissue collection and health monitoring of s

marine mammals in North Carolina and Virginia

2008 NJ Marine Mammal Stranding Center Support and Enhancement for the Marine Mammal S

Program at MMSC

2008 NY Riverhead Foundation for Marine Research and 

Preservation

Operational Support to Enhance Resources for RespTreatment, and Date Collection from Living and Dead Marine Mammals Recovered in New York State
YEAR STATE APPLICANT TITLE

2008 OR Portland State University Enhancement of Diagnostic Capabilities and Extensio

Geographic Coverage for the Northern Oregon/SouthWashington Marine Mammal Stranding Program (NO

2008 OR Oregon State University Enhancing the Capabilities of the Oregon Marine Mam

Stranding Network

2008 TX Texas State Marine Mammal Stranding Network Response, Treatment, and Data Collection from Livin

Dead Marine Mammals Stranded Along the Texas Co

2008 VA Virginia Aquarium Processing archived samples from stranded Tursiops 2008 VA Virginia Aquarium Supporting Expert Response to Stranded Marine Mam

Virginia

2008 WA Makah Tribe Investigations of Marine Mammal Strandings on the M

Indian Reservation

2008 WA The Whale Museum Response and postmortem evaluation of marine mam

stranded in San Juan County, Washington

2008 WA Orca Network Enhanced stranding response, post-mortem examina

diagnostics of stranded marine mammals in Central PSound, Washington. 

2008 WA Cascadia Research Collective Enhanced Reponse to Stranded Marine Mammals in 

Washington Including Searches of Outer Coast BeacSmith Island to Examine Underreporting of Stranding and Follow Up of Unusual Mortalities
APPENDIX L 

MARINE MAMMAL OIL SPILL RESPONSE GUIDELINES

NOAA Fisheries Guidance Document - Draft 4/10/2006 

For Information Only 

 MARINE MAMMAL HEALTH AND STRANDING RESPONSE PROGRAM 

Marine Mammal Oil Spill Response 

Guidelines 

U.S. Department of Commerce 

National Oceanic and Atmospheric Administration 

National Marine Fisheries Service 

Office of Protected Resources 

 Marine Mammal Health and Stranding Response Program 
 

This page left blank intentionally 
 4/10/06 - Draft i

MARINE MAMMAL HEALTH AND STRANDING RESPONSE PROGRAM 

Marine Mammal Oil Spill Response 

Guidelines

Shawn Johnson, Michael Ziccardi 

Wildlife Health Center, School of Veterinary Medicine, University of California, One Shields Ave., Davis, CA 95616 

U.S. DEPARTMENT OF COMMERCE 

Carlos M. Gutierrez, Secretary 

NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION 

Conrad C. Lautenbacher, Jr., Administrator 

NATIONAL MARINE FISHERIES SERVICE 

William T. Hogarth, Assistant Administrator for Fisheries 
MARINE MAMMAL OIL SPILL RESPONSE GUIDELINES 

 4/10/06 - Draft ii

NOTICE 

The National Marine Fisheries Service (NMFS) does not approve, recommend or endorse any 

proprietary product or material mentioned in this publication. No reference shall be made to 

NMFS, or to this publication furnished by NMFS, in any advertising or sales promotion which 

would indicate or imply that NMFS approves, recommends or endorses any proprietary product 

or proprietary material herein or which has as its purpose any intent to cause directly or indirectly 

the advertised product to be used or purchased because of NMFS publication. 

Correct citation of this report is: 

Johnson, S., and M. Ziccardi. 2006. Marine Mammal Oil Spill Response Guidelines. NOAA 

Technical Memorandum.. 

Acknowledgements 

Development and publication of the Marine Mammal Oil Spill Guidelines was made possible with the 

financial support from NOAA Fisheries, National Marine Mammal Health and Stranding 

Response Program and the combined effort of many different interested and willing parties and 

organizations. The bulk of these procedures are based on protocols developed by participant 

organizations within California’s Oiled Wildlife Care Network (OWCN) from years of marine 

mammal rehabilitation and oil spill response experience. These guidelines could not have been 

written without the previous contribution to the field of marine mammal oil spill response by 

Pamela Yochem (Hubbs-SeaWorld Research Institute, San Diego, CA) and Marty Haulena (The 

Marine Mammal Center, Sausalito, CA). Additions and modifications to this document should be 

made regularly as advances in oil spill response techniques are made. Any suggestions for 

additional material or comments on methods included in this document are welcome. 

Many individuals and organizations helped make this publication possible through the generous 

contributions of their time and effort and we offer our sincere thanks to everyone involved. 
MARINE MAMMAL OIL SPILL RESPONSE GUIDELINES 

 4/10/06 - Draft iii

Table of Contents 

Introduction 1

Organizational Structure 4

Stranding Network and Facility Requirements 8

Data Collection 11

Safety and Human Health 13

Wildlife Recovery and Transportation 16

Intake Procedures 20

Animal Washing and Continued Care 24

Disposition 28

Records 32

References 33

Appendices 37

1. Search Effort Log 

2. LIVE Marine Mammal Data Log Form 

 2b. LIVE Marine Mammal Data Log Form, page 2 

3. DEAD Marine Mammal Data Log Form 

 3b. DEAD Marine Mammal Data Log Form, page 2 

4. Oiled Marine Mammal Intake Form 

5. Oiled Marine Mammal Daily Progress Form 

6. Oiled Marine Mammal Evidence Collection Protocol 

7. Petroleum Hydrocarbon Tissue Sampling Protocol 

8. Oil Spill Response Laboratories and Supplies 

9. Oiled Marine Mammal Necropsy Form 

10. Chain of Custody Form 

 10b. Chain of Custody Form, page 2 
MARINE MAMMAL OIL SPILL RESPONSE GUIDELINES 

 4/10/06 - Draft iv

Internet Resources 

NOAA Fisheries, Marine Mammal Health and Stranding Response Program

http://www.nmfs.noaa.gov/pr/health/

NOAA, Damage Assessment and Restoration Program (DARP): 

http://www.darp.noaa.gov/

U.S. Coast Guard Oil Spill Response: http://www.uscg.mil/hq/g-m/nmc/response/index.htm

U.S. Coast Guard Area Contingency Plans: http://www.uscg.mil/vrp/acp/acp.shtml

U.S. National Response Team: http://www.nrt.org/

Wildlife Health Center, UC Davis: http://www.vetmed.ucdavis.edu/whc/

Oiled Wildlife Care Network: http://www.vetmed.ucdavis.edu/owcn/
 

4/10/2006 Draf t 1 

Introduction 

Marine Mammals and Oil: A Brief Overview 

In comparison to marine birds, marine mammals are infrequently affected by oil spill incidents. 

The number of individuals and species affected, as well as the degree of pathological impact of 

such exposure, will depend on many variables, such as the location and size of the spill, the 

characteristics of the oil, weather and water conditions, types of habitats affected, the time of year 

the spill occurs, as well as the behavior and physiology of the marine mammal. Information on 

the effects of oil on marine mammals is sparse, and is mostly a result of the Exon Valdez oil spill 

in Alaska in 1989 and a limited number of exposure experiments on a narrow range of species 

exposed to relatively low doses of oil (Geraci and St. Aubin, 1990). 

The sensitivity of marine mammals to spilled oil is highly variable and appears to be most directly 

related to the relative importance of fur and blubber to thermoregulation. In those species with 

relatively sparse fat stores, direct contact with oil impairs the thermal insulative value of fur thus 

resulting in hypothermia. External exposure can also result in dermal injury and conjunctivitis. 

Internal exposure of oil by ingestion (either by direct ingestion or indirect through food and water 

sources) can result in gastrointestinal ulcers and liver and kidney damage. Inhalation of volatile 

hydrocarbons can result in central nervous system and pulmonary damage and behavioral 

abnormalities. Depending upon the extent of external exposure, the toxicity of the petroleum 

product, the volume ingested or inhaled, the presenting clinical signs, and the species affected, 

some marine mammals exposed to oil may not need rehabilitation. Oil spill responders must 

consider that such procedures involving capturing, holding, treating, and releasing the wild 

animals places stress on the animal, and the consequences of capture and captivity may be a 

greater risk to its well being than contacting oil. Exceptions may include abandoned or moribund 

young pups of any species and species that rely on fur for thermal insulation. These animals will 

most likely require rehabilitation when oiled due to the physical and toxicological effects of 

petroleum exposure. 

Pathological Effects of Petroleum Exposure 

Documented clinical and histopathological effects of oil in pinnipeds and sea otters include 

ambulatory restrictions, thermoregulatory imbalance, central nervous system depression, 

interstitial pulmonary emphysema, aspiration pneumonia, anemia, conjunctivitis and corneal 

edema, gastrointestinal irritation, and hepatic and renal tubular necrosis/lipiosis, and adrenal gland 

dysfunction (Davis and Anderson, 1976; Geraci and Smith, 1976; Engelhardt et al., 1977; 

Engelhardt, 1985; Geraci and St. Aubin, 1988; Geraci and Williams, 1990; St. Aubin, 1990; 

Lipscomb et al., 1993). Small laboratory studies on the effects of oil have been conducted on 

ringed and harp seals (Smith and Geraci, 1975; Geraci and Smith, 1976); however most studies 

have been unable to correlate the degree of oiling with the type of effect and many of these 

lesions may be related to captivity stress or other underlying factors. Changes in acute phase 

proteins and cytokines (e.g. elevated IL-6, haptoglobin and creatine kinase) have been correlated 

with probable petroleum exposure in river otters (Duffy et al., 1993; Duffy et al., 1994). Oiled sea 

otters displayed evidence of hepatic and renal dysfunction as well as anemia in their blood 

parameters (Williams et al., 1995). 
 MARINE MAMMAL OIL SPILL RESPONSE GUIDELINES 

4/10/2006 Draf t 2 

Heavy oiling did not appear to interfere with seal locomotion during the Exxon Valdez oil spill 

(Lowry et al., 1994), but in previous spills seal pups encased in oil have drowned due to their 

inability to swim (Davis and Anderson, 1976). During Exxon Valdez, harbor seals were observed 

exhibiting abnormally tame or lethargic behavior. These observations are most likely explained by 

midbrain nerve damage found in oiled harbor seals and Steller sea lions (Spraker et al., 1994). In 

addition to the acute mortalities associated with the loss of thermoregulation and buoyancy, many 

physiological and behavioral problems have been attributed to internal exposure to petroleum and 

polycyclic aromatic hydrocarbon (PAH) compounds in sea otters. However, many of these 

conditions have been difficult to differentiate from lesions attributed to, or compounded by, 

shock and chronic stress associated with capture and the rehabilitation process (Williams and 

Davis, 1995). It has become clear that animals captured during oil spill responses undergo 

additional stressors that may or may not be offset by the medical care they receive. 

Background 

The purpose of the Marine Mammal Oil Spill Response Guidelines (Guidelines) is to provide a 

foundation for coordination and communication between the National Marine Mammal Health 

and Stranding Response Program participants and other state and federal governmental agencies 

involved in oil spill response and marine mammal conservation and protection. The National 

Oceanic and Atmospheric Administration (NOAA) Fisheries, Office of Protected Resources, 

Marine Mammal Health and Stranding Response Program (MMHSRP) enlisted the University of 

California (UC) Davis, Wildlife Health Center to assist in the development of these Guidelines 

with input and assistance from NOAA’s National Ocean Service, Office of Protected Resources, 

Damage Assessment and Restoration Program (DARP) and NOAA Fisheries, Office of Law 

Enforcement (OLE). The UC Davis, Wildlife Health Center, through its Oiled Wildlife Care 

Network (OWCN) program is among the world’s leading experts on oiled wildlife response 

methods and standards. The primary purpose of the document is to: outline appropriate 

standardized data collection techniques for response activities and damage assessment; define 

chain-of-custody protocols for animal collection, necropsy and sampling; provide 

recommendations for protection of human health and oil spill safety training for responders; and 

present guidelines for best achievable care of oiled marine mammals. Standardization of this 

information between and among oiled marine mammal responders should allow for more 

accurate collection of data for analysis, which then may yield better information on the effects of 

oil on marine mammals and further improvements in oil spill response involving marine 

mammals. These Guidelines by their design do not address overall marine mammal husbandry 

methods in detail, but are intended to provide basic information on oil spill specific issues (such as 

search and collection, transport, emergency care and stabilization), and procedures specific to oil 

spill response. For more information on general marine mammal rescue and rehabilitation, the 

reader should consult references such as Marine Mammals Ashore (Geraci and Lounsbury, 1993) 

and the CRC Handbook of Marine Mammal Medicine (Dierauf and Gulland, 2001). 
 MARINE MAMMAL OIL SPILL RESPONSE GUIDELINES 

4/10/2006 Draf t 3 

Intended Uses 

These Guidelines are intended for use by the NOAA Fisheries MMHSRP, other natural resource 

management agencies, marine mammal stranding networks and rehabilitators, On-Site 

Coordinators, and Potentially Responsible Parties (PRPs) as a guide in: 

 Developing appropriate sections of Area Contingency Plans (ACPs) 

 Stimulating communication and documentation coordination between interested parties 

 Caring for oiled marine mammals 

 Evaluating marine mammal rehabilitation center capabilities for oil spill response 

 Collecting evidence for assessment of impacts on marine mammals 

 Making informed choices during spill responses 

Responses to spills impacting marine mammal will depend upon factors including the size of the 

spill, species involved, type of product spilled, time of year, and location. It is important that spill 

responders and pre-spill planners recognize that the variability in degree of effort and complexity 

in marine mammal response can be significant when comparing small and large events. 

This document is not intended for use as a training manual. Nor is this document an 

exhaustive list of techniques in this field, in which practical knowledge is being continuously 

refined and developed. It is to serve as guidance for acquiring the best achievable care and data 

collection during an oil spill response and should be periodically reviewed and updated. 
 

4/10/2006 Draf t 4 

Organizational Structure 

Organizational Structure of Wildlife Response 

Actions taken to protect wildlife resources follow an organized and agreed-upon cascade of 

agency notifications and activities. All activities of the oil spill response are coordinated through 

the Unified Command (UC) and follow an Incident Command System (ICS) structure as 

standardized by the National Interagency Incident Management System (NIIMS) and modified 

for oil and hazardous substance spill response by the National Response Team (Figure 1., NRT 

2004). The UC is the governing body ultimately responsible for all decision making processes 

during the spill response, and is made up of a Federal On-Scene Coordinator (FOSC) (usually a 

Coast Guard Captain of the Port for the affected area), a State Incident Commander (IC) or OnScene Coordinator (SOSC), and a qualified individual from the Responsible Party (RP), if known. 

When appropriate, local government representatives can be included in the UC. The FOSC has 

the ultimate responsibility for directing the oil spill response if a consensus cannot be reached 

among the members of the UC. Wildlife response activities usually exist within the Operations 

Section of the ICS, though some wildlife actions (primarily baseline assessment and planning) also 

occur with the Environmental Unit of the Planning Section. The Wildlife Branch within the 

Operations Section coordinates and initiates wildlife response activities. Guidance for dealing with 

oiled wildlife is not specifically provided in the National Contingency Plan, therefore the Wildlife 

Branch operational plan is developed uniquely within each Regional and Area Contingency Plan 

based on the specific resources and agency involvement. 

 

Early but prudent initiation of a wildlife response plan and the previous development of the 

Wildlife Branch ensure timely mobilization of dedicated staff, equipment, and volunteers. This 

structure allows for effective lines of communication, making the response effort much more 

efficient. The degree of the wildlife response effort is designed to be flexible and scalable to the 

size of the oil spill - only those positions necessary and appropriate for a specific spill incident are 

filled. 

Trustee Organizations 

Under federal statutes, NOAA Fisheries, National Marine Fisheries Service (NMFS) has 

responsibility for managing and protecting all cetaceans and pinnipeds in U.S. waters, except 

walruses; U.S. Fish and Wildlife Service (FWS) has responsibility for managing and protecting 

manatees, walruses, sea otters, and polar bears. NOAA Fisheries is responsible for the 

administration of the Endangered Species Act (ESA) as it applies to certain cetaceans and 

pinnipeds and the FWS is responsible for the administration of the ESA as it applies to remaining 

marine mammals and terrestrial mammal and bird species. Following an oil spill, specific 

information on wildlife resources at risk and appropriate wildlife response actions are made 

available to the Federal On-Site Coordinator (FOSC) and other members of the Unified 

Command (UC) through representatives of appropriate wildlife resource managers. Therefore, 

the UC must immediately consult with FWS or NMFS whenever a response may affect these 

resources. The Marine Mammal Protection Act (MMPA) prohibits the “take” of sea otters, seals, 

sea lions, walruses, whales, dolphins, and porpoises, which includes harassing or disturbing these 

animals as well as actual harming or killing; however, Section 109(h) of the MMPA allows take by 
 

4/10/2006 Draf t 5 

Federal, State, or local governmental officials, during their official duties, provided the take is for 

the welfare and protection of the animal or public health. Accordingly, the FOSC/UC is 

authorized to take marine mammals during an oil-spill response if to protect the welfare of the 

animal. Section 12(c) of the MMPA allows NMFS to enter into cooperative agreements (e.g. 

Stranding Agreements) that allow stranding network participants marine mammal take in order to 

carry out the purposes of the MMPA. The ESA and its implementing regulations provide special 

provisions for consultations during emergencies (such as oil spills) with FWS and/or NMFS for 

making recommendations to the FOSC to avoid the taking of listed species or to otherwise 

reduce response-related impacts. In some State statutes, management and protection of wildlife 

resources are joint responsibilities between NMFS, FWS and the State. Because of these shared 

trust responsibilities, both federal and state agencies are required to respond to spills, or potential 

spills, that may impact marine mammals. To facilitate efficient and effective coordination during 

an oil spill response, federal and state agencies may consider developing Memorandums of 

Agreement (MOA’s) or Memorandums of Understanding (MOU’s) that pre-designate regional 

primary points of contact, establish lead representatives, and define roles for natural resource 

emergency situations. 

In the wake of the Exxon Valdez spill, Congress passed the Oil Pollution Act of 1990 (OPA 90). 

OPA 90 sets forth an extensive liability scheme that is designed to ensure that, in the event of a 

spill or release of oil or other hazardous substance, the responsible parties are liable for the 

removal costs and damages that result from the incident. A responsible party may be liable for 

removal costs and damages to natural resources, real or personal property, subsistence use, 

revenues, profits and earning capacity, and public services. OPA 90 also set aside a significant 

trust fund that can be utilized quickly to implement a spill response prior to establishment of 

liability. 

OPA 90 directs the appointed trustees to conduct natural resource damage assessments (NRDAs) 

and develop and implement plans to restore, rehabilitate, or replace damaged natural resources. 

Authority to claim damages to natural resources also stems from Clean Water Act (CWA) and 

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Under 

the CWA, federal and state agencies with diverse jurisdictions and missions are directed to 

combine their response and planning efforts in the event of an oil spill or release of another 

hazardous substance under the aegis of a National Contingency Plan (NPC) or an Area 

Contingency Plan (ACP). An Area Contingency Plan must provide for efficient, coordinated, and 

effective action to minimize damage from oil and hazardous substance discharges.In so doing, an 

ACP assigns duties and responsibilities to various federal and state agencies, provides for 

maintenance of necessary equipment and supplies, and establishes Coast Guard strike teams with 

specialized training in oil and hazardous substance control. In addition, an ACP is designed to 

provide for surveillance and notification systems to detect oil spills as early as possible. Further, an 

Area Contingency Plan is to provide for a specific fish and wildlife response plan, developed with 

the advice of expert agencies, to minimize disruptions to fish and wildlife and their habitat. 

Regional and Area Contingency Plans can be located at the U.S. National Response Team website 

(www.nrt.org) and the USCG website: (http://www.uscg.mil/vrp/acp/acp.shtml). 
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Figure 1: Incident Command Structure for Oil Spill Response (NRT 2004) 

Once the FOSC activates the Wildlife Branch, several components of oiled wildlife response can 

be initiated, including reconnaissance to determine species and areas to focus operations, hazing 

of animals to prevent oiling, search and collection for live and dead animals in the spill area, 

treatment and rehabilitation of oiled animals, and release and monitoring of recovered animals. 

The agencies, organizations, and individuals responsible for these functions should be outlined in 

the Area Contingency Plan. An example of Wildlife Branch organization is shown in Figure 2. 
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4/10/2006 Draf t 7 

Figure 2: Wildlife Branch Organization (State of California, Wildlife Response Plan, 2004) 

 

Under the direction of the Wildlife Branch Director (WBD), the principal objectives of Wildlife 

Operations during spill response and cleanup are to: 

 Provide the best achievable care to impacted and/or threatened wildlife 

 Document for the Unified Command the immediate impacts of the oil spill to wildlife 

 Minimize injuries to wildlife 

 Protect wildlife and habitats from adverse effects of wildlife recovery 

To ensure these objectives are achieved with maximum efficiency, the WBD (in coordination 

with the Environmental Unit) manages the activities of the federal, state, and local agencies along 

with commercial and non-profit organizations responsible for wildlife protection and 

management who fall under the authority of the Unified Command during spill response
 

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Stranding Network and 

Facility Requirements 

Wildlife Operation plans should include (where available and appropriate) properly trained 

regional Stranding Network Participants because of their experience with live animal stranding 

response and rehabilitation for the local area. In order for Stranding Network Participants to 

contribute during wildlife response, they must hold a Stranding Agreement or Letter of 

Authorization (MMPA, Section 112(c)) with NMFS/FWS and have received specific oil spill 

training and meet facility requirements for oiled marine mammal rehabilitation. NOAA Fisheries, 

Office of Protected Resources, may include oil spill response authorization in the Stranding 

Agreement with the Participant when it is determined that the Stranding Network Participant 

meets these criteria. Authorized marine mammal rehabilitation organizations should make efforts 

to become engaged in the development of their Area Contingency Plans to ensure their 

involvement during oil spill response. 

Criteria for Evaluating Marine Mammal Rehabilitation Groups 

The following criteria can be used when considering and evaluating marine mammal rehabilitators 

for conducting oil spill response. 

 Holds all necessary permits, Stranding Agreements (NMFS) and Letter of Authorizations 

(FWS) for marine mammal stranding and response activities. 

 Experience in the capture, treatment, and care of oiled marine mammals 

 Knowledge of conducting marine mammal response activities within an Incident 

Command System structure including appropriate communication and notification 

procedures 

 Sufficiently trained (health/safety and animal care), equipped, and experienced 

supervisory staff 

 Ability to train and equip personnel and volunteers for marine mammal response during 

an emergency oil spill response 

 Ability to quickly mobilize to perform marine mammal capture, field evaluation, 

stabilization and transport (including to remote locations if necessary) 

 Access to appropriate facilities for treating and housing oiled marine mammals (including 

adequate animal care, hazardous waste, and personnel infrastructure) 

o Ability to establish and operate marine mammal intake, holding, and isolation 

areas within 12-24 hours of wildlife response activation. 
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o Ability to establish and operate marine mammal cleaning and pre-release areas 

within 72 hours of wildlife response activation. 

 Agreement with a licensed veterinarian experienced in the treatment of oiled marine 

mammals to provide necessary medical care 

 Use of best practices as outlined in the remainder of this document 

Facility Requirements for Marine Mammal Oil Spill Rehabilitation 

General Considerations 

The size of the spill, its location, and the number and species of animals oiled will help determine 

the type and location of a facility that can meet the required need. Not all spill responses will be in 

the vicinity of a permanent rehabilitation facility. Temporary facilities that can care for oiled 

marine mammals in the short or long-term can be established in local, fixed structures, or mobile 

units can be brought to a spill location to set up as a temporary facility. However, it is critical that 

spill responders and pre-spill planners recognize the degree of effort, the unique requirements of 

oiled wildlife care and the complexity required to implement and establish an adequate facility. 

Pre-spill planning is strongly encouraged to achieve wildlife response systems that will adequately 

address the needs of small as well as large rescue efforts as rapidly as possible during a spill. 

There are published standards for the design of facilities housing marine mammals in captivity. In 

the United States, these standards are published by the Department of Agriculture, Animal and 

Plant Health Inspection Service (APHIS, www.aphis.usda.gov/ac/cfr/9cfr3.html) and are a 

requirement for facilities that wish to display animals to the public. They include such items as 

haul-out requirements, pool size and depth, water quality, number of animals to be kept in a 

particular environment, and strict standards for food preparation areas and medications. The 

USDA standards are useful guidelines but may not be appropriate for animals that require 

constant medical attention and handling, or for facilities that only keep animals for a short period 

of time. NMFS is in the process of developing specific marine mammal rehabilitation facility 

guidelines (NMFS/FWS Best Practices for Marine Mammal Stranding Response, Rehabilitation, 

and Release: Pinniped and Cetacean Rehabilitation Facility Guidelines). 

Facility design for rehabilitation centers is an ongoing area of study and no perfect facilities exist 

to suit all needs for each species and age class of marine mammal. Notwithstanding, certain 

principles should be kept in mind when designing an oil spill response facility or when attempting 

to house oiled marine mammals in an existing facility (Davis and Davis, 1995). An ideal facility 

should include: intake/physical exam/evidence processing area; a veterinary hospital with 

isolation capabilities; indoor wildlife housing/caging areas; food storage and preparation facilities; 

animal washing and rinsing areas; drying areas; outdoor pool and pen areas; pathology facilities; 

volunteer training and eating areas (with restrooms); administrative offices with multiple 

phone/fax lines and conference space; storage; and access to a large parking area. 

Minimizing stressors is an important aspect of creating a good rehabilitation environment. 

Specific animal needs must be taken into account when trying to provide adequate housing for 

animals during an oil spill. These needs may be affected by such factors as the animal's species, 

age, physical condition, degree of oiling, and nature of the product with which it was oiled. 
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Housing Requirements and Considerations 

Indoor and outdoor housing should maximize safety to humans and the animals, provide an 

escape-proof enclosure, and minimize visual stress and human traffic. Within an oil spill response 

facility, housing should be set up so that there are appropriate areas for holding animals prior to 

intake, pre-wash assessment and stabilization, post-wash, quarantine, and longer term housing. 

These areas will differ in the amount of access to the animals that is required, the space that each 

animal requires, the degree to which the environmental temperature can be controlled, and type 

(if any) of water requirements (fresh versus salt). Ideally, all of these areas should have separate 

filtration systems. Separate systems are required for pre- and post-wash animals to prevent oil 

contamination of animals that have already been washed. 

Environmental Control: A finer degree of environmental temperature control is required for 

newly admitted animals, neonates, and animals that are more compromised due to poor 

nutritional state, greater extent of secondary effects, or underlying disease. Animals that are 

compromised require easy or limited access to water, haul-out areas, and heat sources such as 

heating pads and lamps, but may need frequent observation to ensure that severely debilitated 

animals are able to move away from heat sources to prevent hyperthermia and burns. Some 

animals may require more frequent handling for monitoring, sample collection, feeding or 

medicating. Housing should minimize stress but maximize accessibility and ease of monitoring 

(Tuomi et al., 1995) 

Ventilation: Adequate ventilation is an extremely important factor for maintaining marine 

mammals in captivity and is more important in oil spill situations to protect against the toxic 

effects of volatile agents and prevent the spread of infectious agents between animals. Ten to 

fifteen air changes per hour has been recommended as adequate for inside animal holding (NIH, 

1985) and these standards should be adhered to if at all possible. Outdoor housing is ideal for 

maintaining ventilation but drawbacks include lack of environmental control, discomfort for 

personnel working with the animals, and more challenging access control by staff. 

Quarantine: The potential for the spread of disease is an important issue to consider for marine 

mammals in captivity. Captured animals, staff and volunteers may carry infectious agents without 

showing signs of disease and could pose a threat to oiled animals. Staff should use effective 

quarantine protocols including foot baths containing appropriate antimicrobial solutions between 

housing areas, cleaning/disinfecting or changing protective clothing between animals, designating 

separate feeding and cleaning equipment for different areas, and minimizing movement of 

animals and personnel between areas. Extra care must be taken in areas where animals with 

infectious diseases are kept and when handling immunocompromised animals. 

Water Supply: Oiled wildlife care facilities require large quantities of water to provide all areas 

simultaneously (e.g., wash/rinse area, pool area, laundry). The quantity should be sufficient to 

provide at a minimum a continuous flow of 4 gallons/minute to all indoor valves and additional 

supply to fill, operate filtration and ozonation equipment, and provide overflows for pools. 

Washing and rinsing areas require temperature-controlled hot water (98-108°F) with water 

hardness of 2-5 grains per gallon at pressure of 40-60 psi. 

Waste Water: Facilities must dispose of all oil and animal wastewater in accordance with 

appropriate Federal, State, and municipal regulations. Oil contaminated water often must be 

contained in separate holding tanks and not released in normal sewer system. 
 

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Data Collection 

Data Collection and Chain-of-Custody Procedures 

Systematic search and recovery, transportation, processing, and treatment of all oil-affected 

wildlife are critical for guiding response actions and gaining an understanding of the short-term 

and long-term consequences of oil spills to wildlife populations. In addition, these data can be 

used after the emergency response for natural resource damage assessment activities. In order to 

track the samples and collect data during oiled wildlife response, the trustee agencies and response 

organizations must adhere to pre-established chain-of-custody and animal identification 

procedures. For tracking purposes, data on oiled animals are compiled on standard data log forms 

(Appendix 2-3). During large-scale responses, pre-identified wildlife agency personnel or their 

agents will complete log forms; however, field and rehabilitation responders should be familiar 

with the forms and their completion for smaller-scale responses and for individual oiled animals 

that present to participating facilities independent of a spill response. In addition to the tracking 

of live animal data, all samples (carcasses, samples, photos, records) that may be used in legal cases 

must be tracked and secured at all times. 

Quality assurance (QA) procedures are necessary to ensure that data are collected in a scientifically 

valid manner. It is important throughout any sampling and analysis program to maintain integrity 

of the sample from the time of collection, through the point of data reporting, to the final sample 

disposition. Proper chain-of-custody procedures allow the possession and handling of samples 

traced from collection to final disposition. Documents needed to maintain proper chain-ofcustody include: 

Field Logbook: All pertinent information on field activities and sampling efforts should be 

recorded in a field logbook. The logbook should enable someone else to completely reconstruct 

the field activity without relying on the memory of the field crew. All entries should be made in 

indelible ink (preferably ballpoint), with each page signed and dated by the author, and a line 

drawn through the remainder of any page. All corrections should consist of permanent line-out 

deletions that are initialed. An example of a Search Effort Log is presented in Appendix 1. For 

tracking and chain-of-custody purposes, all live and dead animals recovered should be identified 

(tagged/marked) in the field and the identification noted on the Search Effort Log. Permanent 

tags will then be applied and logged at the processing facility. 

Animal Logs: At admittance to a wildlife care and processing facility, the animal must be logged 

into the Live Marine Mammal Data Log or Dead Marine Mammal Data Log (Appendix 2-3) and 

all of the boxes on these forms must be completed. All animals collected dead or alive should be 

given a unique log number and identifier (e.g. tag), as well as a Level A data field number, in order 

to track the individual animals through the capture/collection, processing, and for live animals the 

rehabilitation and release process. 
 

4/10/2006 Draf t 12 

Sample Collection and Label: It is necessary to collect an oil sample from each individual 

animal. A detailed protocol for the collection of evidence is provided in Appendix 6. Each sample 

must be identified with a waterproof label that is securely attached to the outside of each sample

 container. Labels must contain the oil spill name, date, species, intake log number and Level A 

data field number of that animal, animal capture location, and flipper tag color and number and 

then sealed with evidence tape or custody seals. Custody seals are used to detect unauthorized 

tampering with the samples. Samples and photo must be properly stored in a secure location that 

has limited and controlled access. 

Intake Form: For live animals, the Oiled Marine Mammal Intake Form (Appendix 4) must be 

completed for each animal. This form contains important questions about the extent of oiling, 

location and depth of oiling, as well as a place for documenting physical examination findings. For 

evidence documentation, a photo of the animal and oil sample must be taken during intake and 

admission into the wildlife care and processing centers (see Intake and Admission Procedures). 

During rehabilitation, each animal must have individual records documenting the treatment and 

care of that animal. Authorization for cleaning and later release must be documented on the Oiled 

Marine Mammal Intake Form and signed by the authorizing authority (i.e. attending veterinarian). 

For resource damage assessment purposes, a photo of the animal with identification (i.e. card with 

animal log number and date) must be taken prior to release. 

Chain-of-Custody Forms: A chain-of-custody record must accompany every sample that is 

removed from the secured location in the wildlife processing and care facilities. The chain-ofcustody form should be supplied by the managing agency (NMFS, USFWS) representative that is 

acquiring the sample. Both the person relinquishing custody of the sample(s) and the person 

receiving the sample(s) must sign the form and ensure that the samples and records are not left 

unattended unless secured properly. An example chain of custody form can be found in 

Appendix 10. 

Tissue Sampling: Tissue samples are collected for either chemical or histological analysis. Only 

after authority is given by the appropriate trustee agency and the Unified Command can 

necropsies be performed by qualified veterinarians and pathologists to collect tissue samples and 

determine cause of death on collected carcasses and mortalities that occurred during 

rehabilitation. Each animal should be photographed prior to sampling and samples collected 

following the sample collection protocols described in Appendix 6. 
 

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Safety and Human Health 

Worker health and safety are of primary importance in any oiled marine mammal rescue and 

rehabilitation effort. The earliest phases of an oil spill are generally the most hazardous to human 

health and safety. Thus, safe practices during field collection of marine mammals must be a 

priority. Rescue programs should not be initiated unless personnel can conduct activities safely. 

As with all spill response activities, the marine mammal rescue and rehabilitation effort needs to 

be coordinated and monitored by the spill response command center operations, safety, and 

medical staffs. A written Site Safety Plan (SSP) must be developed and approved by the spill’s 

Safety Officer for the rehabilitation facility. If field activities are on-going for marine mammal 

response, the site safety plan needs to be expanded to include these activities including any 

specialized equipment that will be used. All staff and volunteers working on the spill must be 

familiar with and sign the SSP prior to work. 

Training for Marine Mammal Rescue/Rehabilitation Personnel

In addition to mastering specific marine mammal rescue and rehabilitation tasks, personnel must 

be trained to recognize and minimize risk of injuries from oil-related and physical hazards 

associated with oil spill response operations prior to being allowed to participate in on-site 

activities. Elements of required and recommended training will vary depending on the tasks of 

the individuals involved in the response. Training-hour requirements and specific courses vary 

with level of involvement, agency policy, and OSHA and state regulations. 

Required Training 

Personnel involved in oil spill response activities must comply with all applicable worker health 

and safety laws and regulations. The primary Federal regulations are the Occupational Safety and 

Health Administration (OSHA) standards for Hazardous Waste Operations and Emergency 

Response (HAZWOPER) published by the U.S. Department of Labor in Title 29 of the Code of 

Federal Regulations (CFR), section 1910.120 (www.osha.gov). Oiled marine mammal responders 

and rehabilitation centers are not specifically addressed by HAZWOPER and training to address 

risks associated with marine mammal stranding and oil spill response personnel may fall within 

the scope and application of the Hazard Communication Standard (“HAZCOM”, 29 CFR 

1910.1200(h)). The OSHA field compliance or Safety Officer should be contacted to ascertain the 

worker training requirements and develop an implementation plan to minimize the hazards of 

exposure to workers involved in cleanup operations. For maximum protection of the 

environment, OSHA has recognized the need to quickly clean-up spilled oil and has empowered 

the OSHA Regional Response Team representative to reduce the training requirements for 

responders engaged in post-emergency response operations as directed by OSHA Instructions 

CPL 2-2.51 (www.osha.gov). State requirements which are more restrictive will preempt Federal 

requirements. Marine mammal stranding network participants are responsible for training and 

certifying their employees and volunteers. 

Recommended Training 

In addition to the training required by Federal regulations, further training is highly recommended 

for safe and efficient operations during a spill response. This guidance is considered a minimum 
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4/10/2006 Draf t 14 

essential training for marine mammal rehabilitators in accordance with the goal of establishing 

best practices. 

Search and collection and transport personnel 

 General oil spill response training 

 HAZWOPER 24hr training 

 Aircraft/boating/ all-terrain vehicle safety 

 First aid/CPR 

 Local geographical knowledge 

 Marine mammal identification and capture techniques 

Rehabilitation Facility Management 

 Marine mammal oil spill response training 

 Incident Command System 

 HAZWOPER 24hr training 

 Crisis management 

 First aid / CPR 

 Media relations 

Rehabilitation/Stranding Network Facility Workers and Volunteers 

(Live and Dead Animal Handling) 

 General oiled marine mammal training 

 HAZCOM - Hazardous Communication training 

 First aid / CPR 

Personal Protective Equipment 

Personal protective equipment (PPE) must be used to protect wildlife response personnel from 

exposure to hazardous substances and dangers associated with animal care activities. To guard 

against injury from marine mammals, all workers should wear approved personal protective 

equipment appropriate to their task. 

Recommended PPE 

Full eye protection, i.e., goggles, safety glasses, or face shield 

Oil resistant rain gear or oil protective clothing (coated Tyvek, Saranex, etc.) 

Gloves (neoprene or nitrile) that are oil resistant and waterproof 

Non-skid shoes/boots that are oil resistant and waterproof 

Ear protection (muff or ear plug type) when using pyrotechnic devices or operating machinery 

Personal flotation device when working on or near water 

Respiratory protection from organic vapor hazards may also be required for some operations. If 

respirators are used, training and fit testing are required. All workers must be trained on the 

proper use and limitations of all personal protective equipment prior to using the equipment. 

Hazardous Substances 

Rescue and rehabilitation workers may be exposed to spilled oil, and must be so informed. Prior 

to handling a contaminated marine mammal, the Material Safety Data Sheet (MSDS) for the 
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4/10/2006 Draf t 15 

spilled material should be reviewed and all recommended precautions followed. Workers and the 

rehabilitation facility shall be periodically monitored, using calibrated instruments and devices to 

determine exposure. Ventilation in all work areas should prevent the buildup of airborne 

contaminants. 

A portion of the rehabilitation facility should be designated for the storage of contaminated 

clothing, equipment, and medical waste until the items can be decontaminated or disposed of 

properly in accordance with the site safety plan.

Volunteers 

Wildlife response programs regularly use volunteers, particularly at the rehabilitation facility. 

Wildlife response managers need to ensure that volunteers are appropriately trained, supervised, 

and informed of all hazards. A comprehensive volunteer management program is an essential 

component of an efficient wildlife response. This management program needs to address, at a 

minimum, volunteer safety, training, supervision, scheduling, and liability. 
 

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Wildlife Recovery and 

Transportation 

Agency Oversight 

Wildlife Recovery and Transportation involves the collection/capture of dead and live oiled 

wildlife and their transport to processing centers. Under the proposed ICS Wildlife Operation 

structure presented in Figure 2, these activities are performed by the Wildlife Recovery and 

Transportation Group, in close coordination with the UC and the state and federal trustee 

agencies. Marine mammal collection by any agency or organization must be done under the 

direction of the UC and under the agreements/permits from the appropriate management 

agencies (i.e., NMFS, FWS). Recovery and Transportation usually include personnel from state 

and federal trustee agencies, approved contractors, and marine mammal stranding network and 

rehabilitation organizations. Trained, qualified volunteers can be used utilized as long as OSHA 

and other training requirements are met and adhered to. 

Search and Collection Guidelines 

Rescue Team: Teamwork is essential to safe, efficient collection of oiled marine mammals. Each 

team should consist of at least two people, and should be outfitted with the resources and 

equipment necessary to complete its assignment. A plan of action should be developed and 

discussed among all search and collection personnel and approved by the Wildlife Branch 

Director prior to entering the search area. Each capture site should be evaluated and strategies 

developed to suit the terrain and species involved. Capture of affected animals should not be 

attempted if adverse weather, sea conditions, cliffs, or other physical and chemical hazards in the 

“hot zone” are present. Communication between the Rescue and Transportation Group and the 

reconnaissance personnel (within the Operation Section or the Environmental Unit) is important 

to maximize the success of search effort. 

Equipment: Prior to a response, ensure that all equipment is ready and in working condition. 

Capture materials should include communication equipment (portable phone or radio), 

specialized vehicles (4-wheel drive with lifting tailgate or crane, adequate floor space, easily 

cleaned, and good ventilation), boats (capture vessel and support vessel), aircraft (fixed wing or 

helicopter), SCUBA gear, nets (type varies by species and location of capture), cages and transport 

boxes (type varies by species), herding boards, personal protection equipment (PPE) and a first 

aid kit for humans. Any injuries to staff or volunteers should be treated immediately and reported 

to the site safety officer. In addition to PPE required by the Safety Officer to protect personnel 

from oil exposure, appropriate attire for capture teams includes closed-toed shoes or boots, longsleeve shirts, long pants, rain gear, coveralls, and organizational identification (e.g., clothing labeled 

with insignia or logo). 

Procedures: Record the details of the beach search effort on the appropriate Form (Search 

Effort Log, Appendix 1) and include data on the start and end of a search segment, observations 

of oiled animals, and detailed info on the stranding and/or collection (location of capture, GPS 

decimal degree coordinates, reason for capture). If oil or medical samples are collected from the 

animal prior to reaching the intake facility, make sure they are labeled properly with a unique field
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4/10/2006 Draf t 17 

 identification number for each animal. For further details on oil sample collection consult 

Appendix 6, Evidence Collection Protocol. 

Domestic animals should not be permitted near the capture location nor should they come into 

contact with marine mammals. Domestic animals should not be allowed in the transport vehicle, 

and if the vehicle has previously been used to transport domestic animals, it should be disinfected 

and cleaned prior to transporting marine mammals. 

Capture: The potential benefits of capture must outweigh potential negative consequences. In 

general, no rescue should be initiated on free-swimming or beached pinnipeds in the vicinity of an 

oil spill unless the animal in question is in obvious distress. Also, no rescue should ever be 

initiated on free-swimming cetaceans in the vicinity of an oil spill, but a rescue should be 

attempted on a beached cetacean. A decision to capture should consider such factors as sex, age, 

reproductive state, and size of individual animal, and their location with respect to other marine 

mammals. Additionally, all captures must be approved by the appropriate trustee agency (NMFS, 

FWS) prior to initiation. 

Capture and transportation of oiled mammals should be performed only by qualified personnel 

who have received the appropriate safety training as well as marine mammal handling and 

restraint training. Because recovery and transportation duties vary with each response and may 

involve more risk than other duties, the Safety Officer will communicate to the Wildlife Branch 

Director what level of training is appropriate for field response personnel; this training may 

include a 24-hour HAZWOPER training (Hazardous Waste Operations and Emergency 

Response), first aid/CPR, water safety, or boat safety courses (see Safety and Human Health). 

The method of capture may vary according to species and situation. Captures should generally be 

considered for isolated individuals on beaches, spits, tide flats or other relatively flat surfaces, 

using herding boards and nets (brail, breakaway or steel frame pole). Less often, captures may be 

attempted from rock jetties, piers, docks or even in the water for severely debilitated animals. 

Long-handled dip nets, floating bag nets, and a net gun have all been used with some success. 

Depending on the species involved, aquatic captures may use tangle nets, float nets, or Wilson 

traps. 

Unless specifically authorized by appropriate trustee agencies, no non-oiled animals will be 

collected during spill incidents. Preemptive captures to prevent the oiling of sensitive species may 

be considered only under dire circumstances at the direction of the UC and trustee agencies and 

when adequate transport and holding facilities exist. Beached cetaceans should not be pushed 

back out to sea without first being examined by a NMFS-approved marine mammal veterinarian 

and the action approved by the NMFS. Prior to being returned to the open ocean, cetaceans 

should be affixed with a NMFS approved tag or brand. 

All wildlife captured during spill responses should if at all possible be retrieved and transported to 

the wildlife processing and care center(s), regardless of the status and condition (i.e. degree of 

decomposition, degree of oiling). In addition, all capture-related information (i.e. location, name 

of captor, GPS decimal degree coordinates, date, and time) must accompany the animal to the 

facility. The presence of such documentation must be verified when processing centers receive 

wildlife from the Wildlife Recovery and Transportation Group. All information necessary to 
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4/10/2006 Draf t 18 

complete either the live or dead mammal log should be collected prior to the animal entering the 

rehabilitation process or storage respectively. 

Transport Procedures 

Prior to transport, field stabilization techniques may be used if it will be more than one or two 

hours until the animal reaches the rehabilitation facility. These techniques may involve assessing 

the animal for hypo- or hyperthermia and treating accordingly; administering oral electrolyte 

solution and subcutaneous fluids; removing large amounts of oil from the eyes and nares; and 

administering emergency medications (under the guidance of a veterinarian). 

After capture and field stabilization, the oiled animal should be placed in a well-ventilated area on 

a stretcher or foam (for small cetaceans) or in a transport box, airline kennel, or cage (depending 

on pinniped species) for transport. Animals should be staged in a quiet, sheltered area or moved 

directly into the transport vehicle. The cage should be large enough to allow the animal to lie 

down in a comfortable position. Only one animal per transport cage is recommended for the 

safety of the animals and to prevent cross-contamination of oil. Females and their pups are most 

safely transported in separate cages, although they should be positioned so that they can hear, see, 

and smell each other. Pinnipeds less than 70 kg (145 lbs) can be transported in large airline sky 

kennels. Aluminum or other lightweight material is recommended to minimize weight of cages 

designed for larger animals. Each cage must be firmly tied or otherwise secured in the vehicle. 

Sea otter transport kennels should be fitted with a raised bottom grate to avoid additional fur 

fouling. Shaved ice or any other form of fresh water ice (to combat dehydration) and chew toys 

(to combat tooth damage, e.g. plastic/rubber dental chews manufactured for large breed dogs) are 

usually provided for sea otters in transport kennels, but food should be offered if transport time is 

greater than four or five hours. 

Animals must be monitored periodically on transports greater than one hour, as directed by a 

response veterinarian. In most cases, sedation during transport is not recommended. Critical cases 

(e.g., unstable, hypo- or hyperthermic animals) may require more frequent monitoring. Personnel 

transporting animals between the field and the rehabilitation center must maintain contact with 

their supervisor at all times so that departure and arrival times may be anticipated. 

Hyperthermic animals may be sprayed gently with water, or ice cubes may be added to the top of 

the cage and allowed to drip onto the animal as it melts. In order to prevent inhalation and 

subsequent drowning by unconscious animals, do not allow water to accumulate in the bottom of 

transport cages. Hypothermic animals should be placed in a sheltered location out of the wind, 

although good ventilation must be maintained to prevent animals and humans from inhaling 

petroleum fumes. Keep in mind that oiled, stressed, or injured seals are not able to regulate their 

body temperature effectively, and their conditions can change within minutes. Animals are 

generally transported in either a pick-up truck or an enclosed van-type vehicle. Adequate 

ventilation must be maintained to protect both humans and animals from inhaling fumes emitted 

by freshly oiled animals. Unless hypothermia is observed or suspected, keep animals damp and 

cool. The preferred air temperature for pinniped transport is 50-68°F (10-20°C) but should not 

exceed 59°F (15°C) for sea otters (Geraci and Lounsbury, 1993; Benz and Britton, 1995). Fur 

seals or sea otters whose coats are oiled or saturated, neonates of all species, and animals with 

extensive wounds or severe emaciation may require higher temperatures compared to minimally 

oiled animals or non-oiled, stranded animals. Keep in mind that human comfort during transport 
 MARINE MAMMAL OIL SPILL RESPONSE GUIDELINES 

4/10/2006 Draf t 19 

may not be synonymous with or sufficient for the temperature and ventilation needs of the 

transported marine mammals. 

Beached Carcass Removal 

Measures must be taken to ensure that dead animals are appropriately collected, identified, 

documented, and not disposed of until approved by the trustees. In addition, the prompt removal 

of disabled and dead oiled and unoiled animals from the environment can be critical to minimize 

the occurrence of secondary oiling, poisoning of predators and scavengers, and decreasing reidentification of carcasses on subsequent days. Since it is not feasible, reliable, or practical to 

attempt to discriminate between spill-related and non-spill-related casualties while conducting 

beach surveys, all carcasses must be collected. For example, scavenged carcasses, animals with 

dark plumage, wet carcasses, or carcasses with oil sheen or small amounts of oil that may be spill 

related are not always identifiable in the field as such. Because all carcasses found within a spill 

area are evidence, they must be handled according to established chain of custody protocols in 

accordance with spill incident-specific instructions (refer to the Data Collection section of this 

document). Each carcass must be labeled with the date, time, location, species (if known), and 

collector’s name; taken to a designated morgue location; logged into the Dead Marine Mammal 

Log form and placed in a refrigerated unit until further processing can be accomplished. If a 

necropsy cannot be performed within 24hrs the carcass should be frozen (see Disposition Section 

for necropsy details). 

Carcass removal, storage, and disposal expenses are considered a response activity cost that 

should be reimbursed to the Stranding Network Participant. It is the responsibility of the 

Participant to notify the Unified Command of current and future carcass storage and disposal 

expenses during the initial cost assessment of the response activity. 
 

4/10/2006 Draf t 20 

Intake Procedures 

Initial Intake Procedures 

While completing intake procedures, it is important to perform a thorough evaluation, collect all 

samples and data, be safe, and minimize the animal handling time. All personnel performing 

intake procedures should wear appropriate PPE including safety goggles, protective clothing, and 

nitrile gloves (or nitrile gloves inside leather gloves). It is best to work in teams of at least two 

(handler, examiner) or three (handler, examiner, recorder) in order to perform the intake in an 

efficient manner. For larger animals, more than one handler may be required. Physical restraint 

devices such as squeeze cages, otter restraint boxes, and stuff bags may be needed for larger 

pinnipeds and sea otters (Geraci and Lounsbury, 1993; Williams and Sawyer, 1995). Some animals 

(e.g., sea otters, adult sea lions) may require chemical restraint for safe handling and examination 

(Williams and Sawyer, 1995; Haulena and Heath, 2001). 

Several different forms must be completed for every animal captured for rehabilitation during an 

oil spill. The animal must first be logged into a Live Marine Mammal Data Log (example in 

Appendix 2) and all of the boxes on that form must be completed. In addition, an Oiled Marine 

Mammal Intake Form (example in Appendix 4) must be completed for each animal. This form 

contains important questions about the extent of oiling, location and depth of oiling, as well as a 

place for documenting physical examination findings. In addition to the intake form, the 

rehabilitation facility’s standard forms for stranded marine mammals can be used to record 

physical exam findings, laboratory values, treatments, and feedings, provided that all information 

is clearly documented and assigned to the specific animal. 

A brief physical examination is performed upon admission of each individual oiled animal (see 

below). A veterinarian or animal care specialist should conduct the examination and treat any 

conditions that are considered to be life threatening. The capture, transport, and intake process is 

extremely stressful and an oiled animal’s condition may be very unstable. The intake area should 

be as dark and quiet as is practical and animals must be monitored closely during the examination 

and intake process. If an animal’s condition deteriorates and a veterinarian is not participating in 

the examination, seek veterinary advice immediately. 

General Intake Procedure for Oiled Marine Mammals 

1. Obtain and Complete Intake Forms 

 Live Mammal Data Log 

 Oiled Marine Mammal Intake Form 

2. Physical Examination 

3. Flipper tag application 

4. Oil sample collection 

5. Photograph 

Animals need to be identified to species and, when possible, age class (pup, yearling, subadult, 

adult) and sex should be determined. Consult charts on age estimation for pinnipeds and sea
 MARINE MAMMAL OIL SPILL RESPONSE GUIDELINES 

4/10/2006 Draf t 21 

 otters from marine mammal guides such as Geraci and Lounsbury (1993), Reeves et al., (1992) 

and Ainley et al., (1980) for species and sex identification. All animals should be tagged or marked 

for individual identification. This can be done with plastic livestock ear tags (e.g., Rototag, 

Temptag), by applying hair dye, colored livestock markers, and bleach marks to the pelage, or by 

clipping a small patch of pelage on the flank in a recognizable pattern (phocids and sea lions only). 

Dye marking and clipping is not advisable for fur seals or sea otters and may be difficult in other 

species depending on the location and extent of oiling. Sea otters and possibly other species may 

be identified using a commercially available pet microchip inserted subcutaneously at the inguinal 

region. 

For legal purposes, it is necessary to collect an oil sample from each individual animal. A detailed 

protocol for the collection of evidence is provided in Appendix 6. Briefly, visible oil should be 

scraped from the fur with a clean wooden spatula and placed into a chemically cleaned glass jar. 

For animals with no visible gross oiling, an affected area is rubbed with a 4x4 piece of fiberglass 

cloth or cotton gauze with forceps or hemostats that have been cleaned with isopropyl alcohol. 

Precautions must be taken to collect the sample without allowing nitrile gloves to touch the oil 

sample or the cloth it is collected on. The oil sample should be placed in a glass container and 

labeled appropriately with the following information: the oil spill name, date, species, intake log 

number of that animal, animal capture location, and flipper tag color and number and then sealed 

with evidence tape and placed in secure freezer. Sampling supplies (glass jars and cloth) can be 

obtained through the trustee agencies. 

 

It is also necessary to take a Polaroid photograph of the oiled animal. The photograph should 

include the entire animal, the oiled region, and if possible, show the flipper tag numbers. After the 

photograph develops, it should be labeled with the same information as the oil sample; the oil spill 

name, date, species, intake log number of that animal, animal capture location, and flipper tag 

color and number. The photograph and oil sample are both pieces of evidence and should be 

securely stored. If samples are to be sent for analysis, a completed Chain of Custody form is 

required and will be provided by the lead trustee agency. 

Physical Examination 

Animals are to be weighed and measured (standard length and axillary girth, xiphoid girth in sea 

otters) and their temperature measured with an electronic thermometer with a flexible thermister 

probe (e.g., Physitemp Model BAT-12 Digital Laboratory Thermometer) inserted 15 cm into the 

rectum. Standard thermometers can be used in sea otters, but do not accurately measure core 

temperatures in pinnipeds. Normal core temperature for sea otters is 99.5-100.6 °F (37.5-38.1 °C) 

and most pinnipeds range from 98-102 °F (Dierauf and Gulland, 2001). If the use of a 

thermometer is not possible, feel the flippers (e.g., icy cold or dry and hot) and observe the 

animal’s behavior (e.g., shivering, agitation) in order to evaluate abnormally high or low body 

temperature. If an animal is dry and alert/active prior to the exam, assume it will overheat with 

handling. 

A complete whole body examination should be conducted, making note of the degree and nature 

of oil contamination. Assess behavior, activity level and alertness; if possible, observe the animal 

in the transport cage prior to handling to evaluate locomotion and central nervous system status. 

Evaluate overall body condition and estimate the percent dehydration. Most stranded animals are 

at least slightly dehydrated (<5%, demonstrated by decreased tear production and subdued 

behavior). More severely dehydrated animals (5-10%, demonstrated by lack of tear production,
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4/10/2006 Draf t 22 

 thick ocular mucus, “sunken” or crusty eyes, dry mucous membranes, skin tenting in otariids, 

curling of the vibrissae in harbor seals, and lethargic or depressed behavior) may need to be 

treated with fluids prior to continuing the examination and intake procedures; however, it is 

preferable to obtain blood samples prior to hydration treatments. 

Due to the risk of being bitten, a thorough oral exam is possible only in anesthetized, dead, 

comatose, and young animals, but a visual inspection of the oral cavity is often possible during 

vocalization in alert animals. Palpate the neck and thorax for evidence of subcutaneous 

emphysema and the musculoskeletal system for fractures, wounds, or swellings. Subcutaneous 

emphysema is often found in the neck and axillary area in oiled sea otters and is an indicator of 

severe pulmonary damage. Palpate the abdomen gently to detect masses, pregnancy, or fluid 

accumulation and observe the urogenital area for urine, feces, or abnormal discharges. 

Routine Blood Sampling 

Following the general examination, blood samples should be drawn for hematology (collected in 

an EDTA anticoagulant, lavender-top tube, LTT) and chemistry panels (collected in a serum 

separator tube, SST, or red-top tube, RTT) and serum banking. In phocids, blood is generally 

drawn from the epidural sinus or ventral (plantar) interdigital veins (at the apex of the web 

between the inner digits) of the hind flippers (e.g., harbor seals, elephant seals). In otariids, the 

caudal gluteal vein and plantar network (dorsal or ventral surface of the hind flipper just medial to 

the lateral digit or just lateral to the medial digit) are used for blood collection (sea lions and fur 

seals). In sea otters, blood may be drawn from the popliteal (saphenous) or femoral vein on a 

non-anesthetized animal using a restraint box and/or stuff bag. Alternatively, the jugular vein can 

be used on an anesthetized otariid or sea otter. 

Blood samples should be collected at least three times during the rehabilitation process: on 

admission/intake, immediately prior to washing, and prior to release. Repeat sampling may not be 

necessary for wash or release procedures, if preformed within 48hrs of previous blood sampling 

or at the discretion of the response veterinarian. At these times, baseline blood work should 

include a complete blood count and standard serum chemistry tests. Normal blood values for 

marine mammal species can be found in Bossart et al. (2001). 

Standard Blood Tests 

Complete Blood Cell counts (CBC): White cell blood count, red cell blood count, hemoglobin, 

hematocrit, mean corpuscular volume (MCV), mean corpuscular hemoglobin concentration 

(MCHC), mean corpuscular hemoglobin (MCH), a differential cell count, platelet and reticulocyte 

counts. One full lavender-top tube (EDTA) (1 or 3 ml) should be taken and refrigerated until 

analysis. 

Chemistry Profile: Albumin, alkaline phosphatase, bicarbonate, bilirubin (total and direct), BUN, 

calcium, chloride, cholesterol, CK, creatinine, globulin, glucose, phosphorus, potassium, total 

protein, sodium, AST (SGOT), ALT (SGPT), GGT, and ratios of albumin:globulin, 

BUN:creatinine, and sodium:potassium. Blood should be placed in a serum separator tube or red 

top tube, allowed to clot, centrifuged, and refrigerated prior to analysis. Excess serum should be 

saved and banked (frozen) at the rehabilitation facility. 
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4/10/2006 Draf t 23 

Special Biomedical Sampling Protocols 

At times, additional protocols may be used that require additional blood samples for other tests 

(e.g., PAH estimation, immune function assays, serum protein electrophoresis, plasma 

chemistries, serological tests for infectious diseases). Other biomedical samples (e.g., urine sample, 

fecal sample, microbiological swab, blubber biopsy) may also be collected at the discretion of the 

response veterinarian. 

Post-examination Intake Procedures 

Initial Treatment 

 Fluid therapy: oral, subcutaneous, intravenous 

 Activated charcoal (ToxiBan) tubing if oil ingestion suspected 

All animals are assumed to be at least 5% dehydrated. Administer isotonic fluids to animals that 

appear to have not ingested oil orally at a rate of 10-20 ml/kg once either orally (e.g., Pedialyte) or 

subcutaneously (lactated Ringer’s solution, LRS). If the animal is alert and is likely to have ingested 

oil (e.g., fur seals during grooming, neonates during nursing), administer activated charcoal slurry 

(ToxiBan, 6 ml/kg) orally. 

Animals that are chemically immobilized for intake procedures or are weak and obtunded should 

not be given oral fluids. Subcutaneous fluids (e.g., lactated Ringer’s solution), may be administered 

instead at 20-40 ml/kg. If ingestion of oil is suspected, ToxiBan slurry (6ml/kg) can be 

administered via a stomach tube just prior to anesthetic reversal (Williams and Sawyer, 1995). 

Extreme care must be taken to prevent gastric reflux and aspiration during this procedure. The 

risks associated with passing a stomach tube must be weighed against the risks associated with 

continued exposure to ingested petroleum. 

Severely depressed animals may require intravenous fluid administration and other medication in 

addition to isotonic fluids. Additional fluid therapy (maintenance fluids plus correction of fluid 

deficits) should be determined by the attending veterinarian, based on an evaluation of blood 

work, concurrent fluid losses, and continuing assessment of the animal’s condition. The fluid 

deficit is calculated by multiplying an animal’s mass in kg x 1000 ml fluid/kg x the percent 

dehydration (e.g., 5% = .05). This should be added to the animal’s daily maintenance fluid 

requirement (at least 40 ml/kg/day) and administered within the first 24 hr if possible. 

Monitoring 

Animals should be regularly monitored during the rehabilitation process. Clinical observations, 

feeding observations (food consumption and/or preferences), and behavior should be written on 

the medical records. Body weight should also be monitored repeatedly during rehabilitation and 

recorded, at a minimum, upon admission, pre-washing, and prior to release. More extensive body 

weight monitoring may be required in critical cases. Physical examinations should be performed 

upon admission, prior to washing, and prior to release with all information recorded on individual 

medical records. Whenever medications are administered, the name of the drug, dose and route 

(oral, SQ, IM, IV) should be recorded as well as the initials of the person who administered the 

medication. Medical records are viewed as potential evidence by the law and should be carefully 

and completely filled out by animal caretakers. 
 

4/10/2006 Draf t 24 

Animal Washing and 

Continued Care 

General Topics Associated With Cleaning 

The facility where oiled animals will be cleaned should be designed to accommodate the variety of 

species that might be cared for at that facility. Each wash station must have adequate space for the 

animals, animal handlers, and restraint equipment that might be necessary. Water hardness should 

be tested before washing animals and adjusted to 3-5 grains of hardness (Clumpner, 1991). Dawn 

dishwashing liquid is the preferred washing product and has been shown to be safe and effective 

for removing oil from the coats of sea otters and harbor seals (Rash et al., 1990). Wastewater 

storage, containment, and removal must meet the requirements of the municipality, city, and 

county. A minimum team of two or three persons usually wash animals. Fur seals and sea otters 

may require teams of four or five persons because the density of their fur requires much greater 

effort. Large animals such as elephant seals may require a washing team with three or four persons 

to properly restrain the animal. Large animals, aggressive animals, fur seals and sea otters may 

require sedation and veterinary assistance for washing and cleaning. 

General Washing Needs 

 Softened water (3-5 gr) 

 Temperature controlled warm water (80-98°F, 27-37°C) 

 Pressured spray nozzles (30-40 psi) 

 Dawn detergent 

 Wastewater storage and removal 

Pre-Wash Evaluation 

Oiled marine mammals will require at least 24 hours of supportive care prior to being washed. 

Initial care is focused on addressing thermoregulatory problems, rehydration, and providing 

nutritional sustenance so animals are no longer in a negative metabolic balance. The washing 

procedure is very stressful; therefore, prior to the procedure, the animal needs to have regained 

strength. In the case of sea otters, they also need to be able to tolerate anesthesia and start to 

groom once recovered. A veterinarian should conduct a pre-wash evaluation that includes a 

physical examination, evaluation of alertness, strength and body condition, and blood parameters. 

If the animal passes the pre-wash evaluation, it is referred to the washing team. 

Removing Tar Patches from Animals 

If the oil present on an animal is a tar patch or very weathered, pretreatment may be necessary. 

This is accomplished by applying warmed (95-98°F or 35°C) olive oil, canola oil, or methyl oleate 

to the affected region. The pretreatment solution should be manually worked into the tarred areas 

for up to 30 minutes or until the tar loosens and can be wiped off using an absorptive pad or 

towel. While pretreating the animal, it is important to monitor the animal’s body temperature and 

be prepared to treat the animal for hyperthermia or hypothermia. Tar removal is necessary for 

furred marine mammals and non-furred marine mammals if the patch(es) are large, potentially 

interfering with thermoregulation, or contribute to toxicity and result in clinical symptoms. 

Clipping away tar patches (with accompanying fur) is recommended unless molt is imminent 
 

4/10/2006 Draf t 25 

because the animal will have a bald patch that could cause reduction of heat retention. This 

procedure could have serious or life-threatening implications for fur seals, sea otters, or debilitated 

animals. 

Washing Harbor Seals, Elephant Seals, Sea Lions 

Sea lions, harbor seals and elephant seals rely on their thick blubber layer for insulation, making 

them less susceptible to hypothermia when they become externally oiled. These species are 

washed with Dawn detergent in thermal-neutral (~ 98°F or 37°C) water. Soap is applied and 

rubbed on the fur until the oil is visibly removed. The detergent can be made into a uniform 

solution by mixing it with water at a 1:1 ratio prior to applying thus making it easier to work into 

the hair and oil. Washing pinnipeds takes between 10-30 minutes depending on the extent and 

type of oil, species and health of the animal, and the proficiency of the staff. An initial quick rinse 

can be done at the wash station and then completed with the animal unrestrained in its pen using 

a pressure nozzle. This modified rinse procedure decreases the duration of manual restraint. In 

general, rinsing should be continued until there is no evidence of oil or detergent in the rinse 

water. Most pinnipeds are placed directly into their outdoor pens to dry. 

General Guidelines for Washing Pinnipeds 

1. Thermal neutral water (~ 98°F or 37°C) 

2. Dawn detergent rubbed onto fur until oil is removed 

3. Pressurized rinse in pen until oil and detergent removed 

4. Air dry in pen 

Washing Fur Seals 

In contrast, fur seals possess a thin subcutaneous fat layer and a thick pelage that thermally 

insulates these animals (Reidman, 1990). Since they rely more heavily on their fur, fur seals are 

washed in a similar fashion to otters. Oiling 30% of a fur seal’s coat will result in a 50% increase in 

heat loss (Geraci and St. Aubin, 1990), emphasizing the need for these animals to be closely 

monitored during the washing procedure. Fur seals are washed using a thermal-neutral (~98°F or 

37°C), 5% diluted Dawn dish washing detergent solution. The diluted detergent solution is gently 

massaged into the fur and, as with other species, the washing duration depends on the extent and 

type of oil, the strength of the animal, and the proficiency of the staff. Fur seals are rinsed with 

fresh, soft (3-5 gr) water under moderate pressure (30-40 psi) with a spray nozzle. This process 

can require up to 40-60 minutes and animals are rinsed until no oil is visible in the rinse water and 

no petroleum odor is detectable on the fur (Davis and Hunter, 1995). For all pinnipeds, animals 

may become hyperthermic during washing in which case they may need to be washed and rinsed 

in cold water. 

Fur seals, which depend on their coat for thermoregulation, may need to be placed in a drying 

enclosure that is warmed with an industrial pet dryer that blows room temperature air (68°F or 

20°C). Animals in drying pens must be monitored for dehydration, hyperthermia, hypothermia, 

and alertness. Once dry and alert, fur seals can be returned to their outdoor pens.

Washing Sea Otters 

Sea otters have the densest fur of any mammal, and, unlike most other marine mammals, replace 

their fur throughout the year instead of undergoing a seasonal molt (Tarasoff, 1974; Williams et 

al., 1992). Otters have guard hairs and many fine under-hairs that are microscopically interlocked 

to trap air, thus providing waterproofing, thermal insulation, and buoyancy. Oil contamination 
 MARINE MAMMAL OIL SPILL RESPONSE GUIDELINES 

4/10/2006 Draf t 26 

causes fur clumping which leads to a loss of insulation and predisposes otters to hypothermia 

from the cold ocean water. 

General Guidelines for Washing Sea Otters 

1. Anesthesia/sedation 

2. Diluted Dawn solution 

3. Temperature controlled warm water 

4. Pressurized rinse (40-60 minutes) 

5. Dry with towels and blow dryers 

6. Anesthesia reversal 

Anesthesia 

Due to their aggressive temperament, sea otters generally require sedation or anesthesia to be 

washed. A variety of anesthetics have been used, however, the current preferred drug 

combination in adult sea otters for nonsurgical procedures is fentanyl (0.22 mg/kg) and diazepam 

(0.07 mg/kg) used together intramuscularly. The opioid antagonist naltrexone at 0.44 mg/kg is 

recommended for reversal, but often 3 - 4 times the total dose of fentanyl administered is needed 

for complete reversal (Monson et al., 2001). While sedated, supplemental oxygen is routinely 

provided either via facemask, or, if the sea otter is immobilized enough to tolerate it, via 

endotracheal tube. During sedation and cleaning, the core temperature of the sea otter must be 

monitored continuously because otters can become hypothermic or hyperthermic very quickly. 

Whenever a sea otter is sedated, bags of crushed ice should be readily available and placed under 

the animal’s neck and flippers if hyperthermia occurs. 

Washing and Rinsing 

Sea otters are washed with multiple applications of diluted (5%) Dawn dishwashing detergent. 

Ideally, washing tables are equipped with three or four well aerated nozzles dispensing 

temperature controlled (28-37 °C, 80-98 °F), softened (3-5 gr.) fresh water. The water temperature 

affects the body temperature and needs to be adjusted according to the otter’s body temperature 

to prevent hyper or hypothermia (Davis and Hunter, 1995; Stoskopf et al., 1997). Four to six 

people are required per washing table, one (with heavy gloves) specifically to hold the head and 

forearms. The detergent is gently massaged into the oiled fur and then rinsed off under moderate 

pressure (30-40 psi) with a spray nozzle. Washing should consist of a wash, rinse, wash, rinse cycle 

until there is no indication of oil in the rinse water and no petroleum odor on the fur. Depending 

on the degree of oiling, washing will usually take from 40-60 minutes. A final rinse with a spray 

nozzle lasting an additional 40 minutes to one hour is essential to thoroughly remove the 

detergent and restore the furs’ water repellency. Otters are initially hand dried with dry, clean, 

cotton terry cloth towels. Once the bulk of the water has been absorbed, the fur is dried with 

commercial pet dryers that deliver a high volume of temperature controlled air (Davis and 

Hunter, 1995). Sea otters become increasingly prone to hyperthermia as their hair is drying and 

cool (room temperature) air may be necessary for drying as the sea otter’s body temperature 

increases. 

Drying 

Following drying, each animal is reversed from the anesthetic and placed in a large, slat-floor 

kennel with a sliding top or other easily accessible dry pen for intensive care monitoring. Animals 

in dry holding should be closely monitored for hyperthermia and fecal, urine, or food debris must 

be rinsed away immediately. When fully recovered from anesthesia, otters should be offered small 

blocks of ice to chew on and food (Davis and Hunter, 1995). Once the animal is stable and 

medical conditions allow, each otter should be moved to a pool with haulout(s) serviced by 
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4/10/2006 Draf t 27 

abundant, clean, chlorine-free salt water (if available). Pools must have high seawater flow rates 

(e.g. 5 gallons per minute for 150 gallon pool) and drain skimmers at water level to collect debris 

from the pool. Fecal and food contamination of the pool water can cause fur fouling and prevent 

restoration of water repellency. Sea otters are not waterproof after washing and drying and must 

reintroduce trapped air into their fur by grooming. 

Post-wash monitoring and care 

During rehabilitation, sea otters need to be monitored around-the-clock by qualified personnel 

familiar with normal sea otter behavior and who are able to recognize clinical signs of distress. Sea 

otters often develop hypothermia post-wash due to lack of air insulation in washed fur and 

inadequate grooming. Otters that appear hypothermic, having difficulty hauling out, or 

experiencing seizures should be immediately removed from the water and evaluated by a 

veterinarian. As health and fur condition improve, otters may be moved to larger pools and/or 

floating holding pens. All pools should have abundant haul-out space. It will generally take a 

minimum of seven to ten days for the fur to recover its water repellency (Tuomi et al., 1995). 

Common Problems Encountered While Washing Animals 

1. Oil is not coming off with Dawn 

 Pretreatment with canola oil, olive oil, or methyl oleate is required. 

2. The animal’s coat is not clean 

 The animal may not have been washed or rinsed adequately. In either case, the animal 

may need to be re-washed or re-rinsed. 

 The wash or rinse water is too hard and mineral deposits are forming on the fur. 

Water hardness should be rechecked to make sure it is 3-5 grains. 

 The holding pool is not clean. Check whether the water is turbid or if there is fish oil 

or debris floating on the pool surface. Water flow may need to be increased or pool 

cleaned. 

Nutritional Guidelines 

The dietary requirements of stranded marine mammals are generally grouped into two categories 

according to age and nutritional needs: unweaned pups and weaned animals. Pups need special 

dietary formulas and feeding regimes based on species and age while free-feeding animals are 

generally fed a diet of good quality fish such as herring. Adult sea otters are usually fed a variety of 

fish and shellfish depending on their preference. Marine mammals also usually need to receive a 

supplemental multivitamin, vitamin E, and salt tablets (if housed in fresh water) with amounts 

based on species and weight. Monitoring fecal production and hydration status is especially 

important when beginning any formula, switching diets, or weaning animals. Recommended diets 

change with continued research and experience and stranding network participants should play an 

important role in the development of dietary protocols for each species and facility. More 

information can be obtained on marine mammal nutrition and energetics from Worthy (2001), 

and hand-rearing and artificial milk formulas from Williams and Davis (1995) for sea otters, and 

Townsend and Gage (2001) and Gage (2002) for pinnipeds. 
 

4/10/2006 Draf t 28 

Disposition 

Release 

The goal in rehabilitating oiled marine mammals is to release healthy animals back into their 

natural environment. Rehabilitators, in consultation with designated trustee representatives 

(NMFS/FWS) must prepare a release plan that is communicated to and authorized by the Unified 

Command through the Liaison Officer. Certain criteria must be met prior to releasing marine 

mammals back into wild populations. For those animals that do not meet release criteria, several 

options are available including additional rehabilitation, euthanasia, or placement in a long-term 

holding facility. 

While little is known about optimal oiled marine mammal release criteria, current 

recommendations are based on information derived from the Exxon Valdez spill and husbandry 

practices at aquaria and rehabilitation centers in the United States. NMFS and FWS have 

developed guidance and criteria for release based on optimizing the chances for survival and 

minimizing the risk to wild populations (Best Practices for Marine Mammal Stranding Response, 

Rehabilitation, and Release – Standards for Release, http://www.nmfs.noaa.gov/pr/health). The 

Standards for Release document describes how to characterize and assess animals using several 

parameters. 

Standards for Release 

1. Historical Assessment 

2. Developmental and Life History Assessment 

3. Behavior Assessment and Clearance 

4. Medical Assessment and Clearance 

5. Release Logistics 

6. Post Release Monitoring 

Current criteria require that animals show normal species-specific behavior (feeding, swimming, 

and diving), adequate body weight for age class and species, pelage proven to be in good 

condition, hematological and serum chemistry values within the normal range, no evidence of 

infectious diseases, and physical exam findings should be unremarkable. Other ancillary tests (e.g. 

Leptospira titer, morbillivirus titer, microbiological cultures, urinalysis, fecal examinations, etc.) may 

also be performed on a case-by-case basis depending on individual animal and population level 

concerns. The Unified Command will decide upon the location of the release with guidance from 

the trustee agencies 

Upon approval for release by UC, an exit photo of each marine mammal must be taken and 

specifics of the release (location, time, personnel) recorded for Natural Resource Damage 

Assessment purposes. 

Post-release monitoring, if at all possible, should be undertaken during marine mammal releases 

following oil exposure using radio or satellite telemetry. This effort should focus on survival rates, 

behavior, and reproductive success following oil contamination and rehabilitation, thus enabling 
 MARINE MAMMAL OIL SPILL RESPONSE GUIDELINES 

4/10/2006 Draf t 29 

oiled marine mammal responders to evaluate the efficacy of oiled marine mammal care. Postrelease monitoring is not usually considered a response activity expense and must be funded by 

the stranding network participate, trustee agency or NRDA. 

Mortalities 

All oiled dead marine mammals should be collected from beaches and taken to a designated 

morgue. Dead animals should be logged in at the morgue using a Dead Marine Mammal Data 

Log (example in Appendix 3). Under certain circumstances, an oiled animal may need to be 

humanely euthanized in order to alleviate suffering. Animals that die during an oil spill response 

must have this disposition information recorded on their individual animal record as well as on 

the Live Marine Mammal Data Log (Appendix 2). The carcass should be identified with a written 

tag including the species name, date of stranding and/or admission, date of death, and the flipper 

tag (if a tag was affixed prior to death). If a flipper tag is present, it should remain with the carcass 

until final disposition of the carcass. The carcass should be refrigerated or kept on ice until a 

necropsy is performed. If a necropsy cannot be performed within 24 hours of death, the carcass 

needs to be frozen. 

Euthanasia 

During an oil spill response, there are circumstances under which it may be necessary to humanely 

euthanize animals. For each spill where marine mammal rehabilitation is undertaken, the 

rehabilitator must prepare a written euthanasia plan in consultation with the trustee representative. 

Euthanasia is appropriate for oiled animals with injuries that will render it unable to survive in the 

wild or unsuitable for use in captivity. If animals are euthanized in the field, they are collected 

following the procedures outlined in the Recovery and Transportation section of this document. 

To prevent secondary contamination or poisoning, euthanized carcasses are never left in the field. 

Necropsy 

Necropsies may be performed concurrent with response activities to identify cause of death in 

order to differentiate between a natural versus pollution related mortality. Fatalities to apparently 

un-oiled wildlife may necessitate necropsies to determine if death was caused by human 

interactions or if sub-apparent oil exposure or ingested petroleum contributed to the mortality. 

Additionally, captivity-related diseases may necessitate necropsies be performed on animals that 

die during rehabilitation to identify potential pathogens or husbandry techniques that are 

detrimental to recovery. 

Prior to performing a necropsy on an oiled marine mammal, specific permission must be 

obtained from Unified Command and the appropriate NMFS/FWS enforcement officer. The 

spill response veterinarian-of-record should conduct or supervise all necropsies, in consultation 

with the designated representative FWS or NMFS enforcement officer. In most cases, a veterinary 

pathologist with specialized training on marine mammals will be asked to perform the necropsy. 

Necropsy methods and techniques are diverse, but general procedures for marine mammal 

necropsies can be found in Rowles et al. (2001), Galloway and Ahlquist (1997), and Geraci and 

Loundsbury (1993). Specific protocols have also been developed for some marine mammals 

including phocids (Winchell, 1990), Killer whales (Raverty and Gaydos, 2004), Right whales 

(McLellan et al., 2004), and Hawaiian Monk seals (Yochem et al., 2004). These species specific 

procedures should be followed whenever possible in order to maintain consistency with previous 

data. Prior to conducting a necropsy, the trustee agency and veterinarian should agree on which 

forms to use; which samples to collect; how those samples will be prepared (e.g., formalin or 
 MARINE MAMMAL OIL SPILL RESPONSE GUIDELINES 

4/10/2006 Draf t 30 

frozen), stored, and shipped; and where samples will be analyzed. Specific oil spill necropsy 

information and forms are detailed in Appendix 7-9. Tissue samples for standard histopathology, 

disease profiling, and petroleum hydrocarbon analysis should be collected. Sampling for oil 

exposure, must be performed under specific conditions detailed in Appendix 7, in order to 

prevent contamination of the sample. Necropsy reports are filed and all samples handled and 

stored using appropriate chain-of-custody protocols, as discussed previously (Data Collection) 

and provided by the trustee representative. 

Laboratories performing the petroleum analysis must be contacted as soon as possible in order to 

verify that sampling protocols and sample sizes are consistent with that specific laboratory 

requirement. Considerations in choosing the lab should include details of forensic capabilities 

(ability to produce legally defensible results), quality assurance and quality control (QA/QC), and 

consistency with the analysis of other materials from the spill. Results can vary between labs and 

data should be comparable between the environmental and tissues of the different species 

sampled. Appendix 8 lists laboratories (not an exhaustive list), with expertise in petroleum 

hydrocarbon chemistry that can be contacted for oil spill sample collection and analysis 

information. Petroleum hydrocarbon analysis is a reimbursable response expenses if pre-approved 

by the UC. However, often the RP (responsible party) assumes ownership of the oil and analysis 

may not be preformed. 

Petroleum and Polycyclic Aromatic Hydrocarbons (PAH) Analysis 

In general, all crude oils are mixtures of the same hydrocarbon and non-hydrocarbon compounds, 

but vary in the percent composition of these compounds. Natural weathering of oil in the 

environment also results in highly variable compositions. Because of the continual dynamic 

changes in spilled oil, it can be difficult to identify and quantify all PAHs potentially present in or 

on an animal in the aftermath of an oil spill. Oil and tissue samples collected from marine 

mammals can be analyzed to determine the total amount of PAHs in tissues and identify and 

quantify dangerous PAHs that may have caused clinical and pathological effects. Samples can also 

be tested to characterize and fingerprint petroleum hydrocarbons to determine their source. 

Determining source-dependent petroleum exposure during an oil spill using GC/MS or HPLC 

techniques on marine mammal tissues requires baseline knowledge of petroleum hydrocarbon 

levels and composition in the spill area and of the spilled oil. At present there are few data 

available on PAH levels in marine mammals inhabiting North American coastal waters. Studies 

have only measured PAH levels in seals and whales from the Eastern Canada (Hellou et al., 1990, 

Zitko et al., 1998) and Northeastern United States (Lake et al., 1995). Overall, the low 

concentrations of bioaccumulated PAHs in tissues from these marine mammals are fairly similar 

to those reported in atmospheric fallout PAHs from combustion sources (Zitko et al., 1998). 

Alkylated and heterocyclic PAHs are the predominant forms of PAHs in oil and coal products, 

and can be missed if tissues are tested only for the 16 traditionally-studied, parent PAHs listed as 

priority pollutants by the Environmental Protection Agency (EPA) and World Health 

Organization (WHO) (Means 1998). Different members of the isomeric alkylated PAHs exhibit 

differential toxicity, diffusion, and degradation rates, further emphasizing the importance of 

compound-specific analysis. With the lack of baseline PAH levels from marine mammals, control 

samples for comparisons were harvested at the time of Exxon Valdez oil spill from animals 

inhabiting nearby non-oiled areas (Mulcahy and Ballachey, 1994; Frost et al., 1994). 
 MARINE MAMMAL OIL SPILL RESPONSE GUIDELINES 

4/10/2006 Draf t 31 

In experimental exposure studies (both immersion and ingestion) involving ringed seals (Phoca 

hispida), differences in detectability of PAHs in various tissues were noted (Engelhardt et al., 1977). 

In the immersion experiment, PAHs were highest in urine and bile, less elevated in blood and 

plasma, and lower in tissues (lowest in lung) at 2 days post-immersion. Tissue sampling in the 

ingestion study was limited with PAHs highest in blood, and higher in liver and blubber 

compared to muscle. These studies illuminate the importance of selecting appropriate tissues for 

PAH analysis. Specific tissue collection techniques are provided in Appendix 7. 
 MARINE MAMMAL OIL SPILL RESPONSE GUIDELINES 

4/10/2006 Draf t 32 

Records 

The importance of recording information cannot be over-emphasized. Record collection 

enhances individual animal care, response evaluations, and the ability to accurately characterize the 

best practices for appropriate care. In-house records are maintained at the rehabilitation facility 

and copies provided to the trustee agency. Final reports, including chain-of-custody and sample 

collection records, must be delivered to the trustee agency within 30 days of the date the Federal 

OSC declares the response closed. 

Scientific Records 

The following types of records are necessary to preserve vital information for scientific study, 

natural resource damage assessment, and improved rehabilitation practices and techniques: 

 Oiled mammal sighting: records and maps for all reports of oiled mammals 

 Search Effort Log 

 Live Mammal Log 

 Dead Mammal Log 

 Marine Mammal Intake Form 

 Rehabilitation Records: documents care for each animal, including feedings, 

treatments, medications, normal/abnormal activities. 

 Lab Analyses Report: identifies all samples sent to labs, requested analyses, lab results. 

 Marine Mammal Stranding Report - Level A Data (NOAA 89-864, OMB #0648-

0178) 

 Marine Mammal Rehabilitation Disposition Report (NOAA 89-878, OMB #0648-

0178) 

 Human Interactions Form 

 Necropsy Report 
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4/10/2006 Draf t 33 

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Appendices 

1. Search Effort Log 

2. LIVE Marine Mammal Data Log Form 

 2b. LIVE Marine Mammal Data Log Form, page 2 

3. DEAD Marine Mammal Data Log Form 

 3b. DEAD Marine Mammal Data Log Form, page 2 

4. Oiled Marine Mammal Intake Form 

5. Oiled Marine Mammal Daily Progress Form 

6. Oiled Marine Mammal Evidence Collection Protocol 

7. Petroleum Hydrocarbon Tissue Sampling Protocol 

8. Oil Spill Response Laboratories and Supplies 

9. Oiled Marine Mammal Necropsy Form 

10. Chain of Custody Form 

 10b. Chain of Custody Form, page 2 
 

Appendix 1. Search Effort Log 

Search Effort Log 

Please record all beaches searched even if no animals are found. 

Spill Name: ___________________________________ Date: ___________________ 

Searchers: ________________________________________ 

Note: Time should include all time spent on the beach, even when backtracking. North and south endpoints should be 

GPS pts. If not, please provide a good description of the area covered. For collected animals, put GPS location here. 

Beach Name Start 

Time

End 

Time

North/West 

Extreme 

(Lat/Long)

South/East 

Extreme 

(Lat/Long) 

Total 

Distance 

Searched

Method (foot, 

ATV, scan)

Mammals 

Collected 

Note: 

(live/ dead, GPS, 

ID # )

A 

B

C 

D

E

F 

G

 

H

 

I

 

J

K

 
 

Appendix 2. Live Marine Mammal Data Log 
 

Appendix 2b. Live Marine Mammal Data Log, page 2 
 

Appendix 3. Dead Marine Mammal Data Log 
 

Appendix 3b. Dead Marine Mammal Data Log, page 2 
Oiled Marine Mammal Intake Form

Spill Name: Level A Field #: Log Number: CAPTURE

Capture Date/Time: Capture Location:

Field Band: Collector:

PROCESSING

Intake Date/Time: Species:

Tag Color/#: Examiner’s Signature: 

EXT. OIL ID

Signs of Oiling Oil Visible Skin Burns Smell Area Oiled Head Body Multiple Entire

Oil Color Black Brown Clear Other Depth of Oiling Deep Moderate Surface

% Oiled <2% 2-25% 26-50% 51-75% 76-100% Samples Hair Swab Photo

PHYSICAL EXAM

Weight/Temp. grams °F Age Pup Sub-adult Adult Unknown

Std Length/Girth cm cm Sex Male Female 

Heart Rate WNL beats/min. Body Condition Normal Thin Emaciated

Resp. Rate WNL breaths/min. Attitude BAR QAR Nonresponsive Seizing

Dehydration None Mild Moderate Severe CRT/mm color Sec. / Pink Pale White Purple

Human Interaction Yes No Type: Boat Collision, Shot, Fisheries, Other:

Neurologic NSF Other:

Head/Mouth NSF Other:

Eyes/Ears NSF Other:

Heart/Lungs NSF Other:

Gastrointestinal NSF Other:

Musculo-skeletal NSF Other:

Integument NSF Other:

Comments

TX-DX Blood taken? HCT LTT RTT GTT Toxiban: yes no time: 

Pre-wash Exam: __________________________ Date Washed : Weight: Bloodwork Attached

DISPOSITION

Disposition Exam: __________________________ Exam Date: Weight: Bloodwork Attached

Disposition Date: Disposition Location: 

Disposition Status: RELEASED DIED EUTHANIZED TRANSFERRED RETAINED Necropsied by: 

Flipper Tag No.: Location: RF LF RH LH

TAG #: SPECIES:

Veterinarian Signature

Veterinarian Signature
Appendix 5. Oiled Marine Mammal Daily Progress Form 
Appendix 6. Oiled Marine Mammal Evidence Collection Protocol 

The photograph and oil sample are both considered to be legal evidence therefore it is important 

that the following procedures are followed closely. 

Photograph Evidence 

1. Use a Polaroid camera (if possible). 

2. Photograph should include the entire animal, highlighting the oiled region, and if possible, 

the tag number. 

3. Label the photograph with Spill Name, Date, Species, Log #, Capture Location, and Tag 

# and Color. 

Sample Collection Techniques for Visible Oiling 

1. Scrape visible oil from fur/skin with wooden spatula (tongue depressor). 

2. Place oil covered spatula in solvent-rinsed glass jar with a Teflon-lined lid (e.g. I-Chem) 

and break off the remaining un-oiled portion, allowing the lid to close. If jar is not 

available, wrap sample in aluminum foil (dull side to sample). 

Note: Avoid touching /contaminating oil sample with your nitrile gloves. 

3. Label the glass jar (use waterproof labels). 

Label must include: Spill Name, Log #, Species, Tag #, Arrival Date, Sampling Date, 

and Capture Location. 

4. Fill out Custody Seal and apply it across the lid of the jar and onto the sides of the glass. 

5. Keep sample refrigerated or on ice until it can be stored. 

6. Lock sample in a -20°C (or colder) freezer. 

Sample Collection Techniques for No Visible Oiling 

1. Rub an affected area with a 4x4 fiberglass or cotton cloth (or gauze) with sterile forceps 

or hemostats that have been cleaned with isopropyl alcohol. 

Note: Do not allow the nitrile gloves to touch the oiled area or the cloth. 

2. Place the oiled covered cloth into a solvent-rinsed glass jar with a Teflon-lined lid. 

3. Seal and fill out the information on the waterproof label (as above). 

4. Fill out the Custody Seal and apply it across the lid of the jar and onto the sides of the 

glass. 

5. Keep sample refrigerated or on ice until it can be stored 

6. Lock sample in a -20°C (or colder) freezer. 

All evidence should be securely stored and refrigerated/frozen until the Wildlife Branch Director 

provides further instructions. If samples are to be sent for analysis, a Chain of Custody Form is 

required. 
Appendix 7. Petroleum Hydrocarbon Tissue Sampling Protocol 

Supplies for sampling 

All instruments used in handling (e.g. scalpels and forceps, cutting boards) or storing (e.g. jars, foil, 

sheets) samples must be made of a non-contaminating material consisting of stainless steel, glass, 

Teflon, or aluminum. 

 - Solvent-rinsed glass containers with Teflon-lined lids for tissues 

- Solvent-rinsed Teflon sheets for tissues 

 - Aluminum foil (if Teflon sheets are not available) sample to the dull side 

 - Sterile syringes and needles 

 - Amber glass vials or glass vials covered with foil with Teflon lids (for bile, urine) 

 - Teflon screw top vials (for blood storage and urine) 

 - Stainless steel scalpels, knifes, forceps 

 - Isopropyl alcohol (99.9% pesticide free IPA) to rinse instrument 

- Wooden tongue depressors (can be used to handle tissues if necessary) 

 - Whirl-pak bags or Zip-lock freezer bags 

 - 10% buffered formalin and appropriate containers for histopathology samples 

- Permanent marker or pen 

 - Evidence/Custody tape and labels 

 - Sample Log/Chain of Custody forms 

Sampling Protocol 

 

Tissues to collect for petroleum hydrocarbon analysis in order of preference: 

 

a. bile 

b. urine 

c. whole blood 

d. stomach and intestinal contents 

e. blubber/fat 

f. liver 

g. kidney 

h. lung 

i. intestine 

j. brain 

k. muscle 

i. Samples taken for analysis should only be collected from alive or freshly dead 

animals. If a necropsy cannot be performed within 24 hrs after death, the carcass 

should be frozen for later examination. 

ii. Recommended minimum sample size is 10-20 g of tissues (approx. 1-2 

tablespoons) and 5 ml for fluids (blood, urine, bile, feces, stomach contents). 

However, analysis can be performed on as little as 100 L of bile; therefore collect 

whatever amount is present. 
Appendix 7. Petroleum Hydrocarbon Tissue Sampling Protocol, page 2

iii. Fluids such as blood, urine, and bile should be collected using sterile syringes or 

pipettes and transferred to Teflon vials (blood) or amber glass vials (bile, urine). 

iv. Use powder-free nitrile gloves. Vinyl gloves are an acceptable alternative. Avoid 

contact of gloves with samples. 

v. Scalpels, knifes, and cutting tools used for tissue collection should be cleaned and 

rinsed with isopropyl alcohol between tissues. If heavily contaminated with oil, 

instruments can be cleaned with detergent (e.g. Dawn), rinsed with water, and then 

rinsed with alcohol. 

vi. Samples are stored preferably in solvent-rinsed Teflon-lined glass jars, labeled, and 

secured with evidence tape/custody seal. If glass jars are not available, samples can be 

placed in Teflon sheets or aluminum foil (dull side to sample) and stored in whirlpaks/freezer bags. 

vii. If samples/tissues have come in contact with a contaminating material (e.g. plastic 

bag), collect and store a representative example of that material (e.g. plastic bag) using 

the same method as for collecting tissues. 

viii. Collect a representative sample of each tissue (< 1 cm thick) preserved in 10% 

buffered formalin for histopathology. Duplicate hydrocarbon and histology samples 

whenever possible. 

ix. Each sample must be labeled with Spill Name, Log #, Level A Field #, Species, 

Tag#, Arrival Date, Sampling Date, and Capture Location and securely stored. 

x. Samples for PAH analysis should be chilled immediately on ice/refrigeration and then 

frozen as soon as possible to -20oC or colder in a locked freezer. Histopathology 

samples are stored at room temperature. 

All evidence should be securely stored and refrigerated/frozen until the Wildlife Branch 

Director provides further instructions. If samples are transferred to a different location or 

sent for analysis, a Chain of Custody form is required. A Chain of Custody form can be 

found in this document, but are often provided by the laboratory. 

Shipping: 

Ship samples frozen on blue ice or with ~5 lbs dry ice according to laboratory specification using 

Federal Express (FedEx). FedEx follows IATA regulations for shipping hazardous materials and 

maintains chain of custody record by tracking packages. 

Sampling supplies such as jars, label, and custody seals are often supplied by the analytical 

laboratory and are produced by: 

I-ChemTM Brand, Certified 300 Series jars 

Order: 1-800-451-4351, www.ichembrand.com
Appendix 8. Oil Spill Response Laboratories

Laboratories with tissue petroleum hydrocarbon analysis expertise 

Northwest Fisheries Science Center 

2725 Montlake Boulevard East 

Seattle, WA 98112-2097 

Jon Buzitis, (206) 860-3309 

Gina Ylitalo, (206) 860-3325 

Alaska Fisheries Science Center 

Auke Bay Laboratory 

11305 Glacier Highway 

Juneau, Alaska 99801-8626 

Jeep Rice, (907) 789-6020 

Petroleum Chemistry Laboratory 

Office of Spill Prevention and Response 

California Department of Fish and Game 

1995 Nimbus Rd 

Rancho Cordova, CA 95670 

(916) 358-2803 

TDI-Brooks International

1902 Pinon 

College Station, TX 77845 

(979) 693-3446 

Thomas McDonald, (979) 220-3821 

Alpha Woods Hole Laboratories

375 Paramount Drive 

Raynham, MA 02767 

Peter Kane, (508) 822-9300 

Zymax Forensics 

71 Zaca Lane 

San Luis Obispo, CA 93401 

(805) 544-4696 

Alan Jeffrey, (805) 546-4693 

Mote Marine Laboratory 

1600 Ken Thompson Parkway 

Sarasota, Florida 34236 

(941) 388-4312 

Dana Wetzel, (941) 388-4441 

Geochemical & Environmental Research

Group (GERG) 

Texas A&M University 

833 Graham Road 

College Station, Texas 77845 

(979) 862-2323 

The laboratory should be able to perform analysis of the 16 traditionally-studied, parent PAHs 

listed as priority pollutants by the Environmental Protection Agency (EPA) in addition to the 44 

alkylated and heterocyclic PAHs. 

Unified Command and Trustee Agencies will make final decision on laboratory use.
Appendix 9. Oiled Marine Mammal Necropsy Form 
Appendix 10. Chain of Custody Form 
Appendix 10b. Chain of Custody Form, page 2 
THIS PAGE INTENTIONALLY LEFT BLANK 
APPENDIX M 

SOCIOECONOMIC INFORMATION SUMMARY TABLES

M-1

Table 1: Summary of overall statewide information on veterinary services 

State Number of 

Establishments 

Revenues and Receipts 

($000’s) 

Annual Payroll 

($000’s) 

Number of Paid 

Employees 

Atlantic/Gulf of 

Mexico Region 

 

Alabama 470 215,658 66,007 3,647 

Connecticut 308 278,984 101,581 3,555 

Delaware 57 54,598 19,773 760 

Florida 1,665 1,027,526 337,264 14,363 

Georgia 721 456,376 157,582 7,242 

Louisiana 393 191,983 58,361 3,231 

Maine 149 96,997 34,837 1,298 

Maryland 466 350,277 129,439 5,218 

Massachusetts 448 374,325 145,196 5,371 

Mississippi 238 104,586 31,209 1,642 

New Hampshire 155 109,833 36,762 1,467 

New Jersey 548 487,464 185,615 6,126 

New York 1,130 934,481 321,104 12,124 

North Carolina 720 510,742 180,959 8,000 

Pennsylvania 940 618,142 205,655 8,884 

Rhode Island 75 56,751 20,800 766 

South Carolina 326 189,719 61,557 3,060 

Texas 2,010 1,224,701 389,384 17,405 

Virginia 684 503,041 191,682 8,221 

Puerto Rico 85 23,846 4,257 302 

Virgin Islands1

 9 3,330 845 35 

 

Pacific Region 

Alaska 60 40,411 15,051 621 

California 2,445 1,948,390 660,464 24,733 

Oregon 464 306,031 105,358 4,624 

Washington 685 439,702 139,487 6,041 

 

Pacific Islands 

Region 

Hawaii 77 51,308 16,447 656 

Guam 4 2,078 595 37 

American Samoa1

 4 59 1 2 

Commonwealth of 

the Northern 

Mariana Islands1 8 1,780 450 34 

2002 Economic Census 

North American Industry Classification System (NAICS) code 541940 1

 NAICS code 5419 which includes veterinary services as well as other sub-industries 
M-2

Table 2: Summary of overall statewide information for all zoos, aquariums, and botanical gardens 

State Number of 

Establishments 

Revenues and 

Receipts ($000’s) 

Annual Payroll 

($000’s) 

Number of Paid 

Employees 

Atlantic/Gulf of 

Mexico Region 

 

Alabama 6 9,815 4,884 257 

Connecticut 7 28,102 9,156 346 

Delaware 1 D D a 

Florida 56 123,503 43,203 2,448 

Georgia 16 45,331 16,489 692 

Louisiana 13 D D f 

Maine 8 3,965 1,548 44 

Maryland 8 D D f 

Massachusetts 17 55,603 18,742 776 

Mississippi 2 D D b 

New Hampshire 1 D D a 

New Jersey 10 12,567 5,587 276 

New York 48 266,257 83,410 2,457 

North Carolina 13 7,992 2,409 95 

Pennsylvania 26 98,672 32,665 1,365 

Rhode Island 1 D D b 

South Carolina 11 34,679 8,493 419 

Texas 37 140,819 44,071 2,232 

Virginia 11 8,584 4,438 247 

Puerto Rico2

 18 13,690 3,714 218 

Virgin Islands2 5 3,583 973 48 

 

Pacific Region 

Alaska 3 D D b 

California 46 272,488 105,438 3,687 

Oregon 11 15,067 6,075 255 

Washington 16 29,801 5,670 204 

 

Pacific Islands 

Region 

Hawaii 20 27,701 7,994 390 

Guam N/A N/A N/A N/A 

American Samoa N/A N/A N/A N/A 

Commonwealth of the 

Northern Mariana 

Islands2 1 D D a 

2002 Economic Census 

NAICS code: 712130 

D = Information withheld by Census to avoid disclosing data for individual companies 

a = 0-19 employees 

b = 20-99 employees 

f =500-999 employees 

2 NAICS code 712 which designates museums, historical sites, and similar institutions. This category includes zoos 

and aquariums. 
M-3

Table 3: Summary of statewide information on zoos, aquariums, and botanical gardens with 

federal tax-exempt status 

State Number of 

Establishments 

Revenues and 

Receipts ($000’s) 

Annual Payroll 

($000’s) 

Number of Paid 

Employees 

Atlantic/Gulf of 

Mexico Region 

 

Alabama 6 9,815 4,884 257 

Connecticut 6 D D e 

Delaware 1 D D a 

Florida 22 60,756 22,323 979 

Georgia 11 D D f 

Louisiana 6 D D f 

Maine 6 D D b 

Maryland 6 D D f 

Massachusetts 13 50,387 17,125 676 

Mississippi 2 D D b 

New Jersey 7 D D e 

New York 34 237,360 75,523 2,219 

North Carolina 6 D D b 

Pennsylvania 18 95,617 31,483 1,314 

Rhode Island 1 D D b 

South Carolina 5 10,703 3,793 165 

Texas 22 131,268 41,775 2,102 

Virginia 5 6,737 3,807 185 

Puerto Rico N/A N/A N/A N/A 

Virgin Islands N/A N/A N/A N/A 

 

Pacific Region 

Alaska 2 D D b 

California 32 268,086 104,104 3,622 

Oregon 7 12,822 5,289 210 

Washington 12 D D c 

 

Pacific Islands 

Region 

 

Hawaii 12 D D c 

Guam N/A N/A N/A N/A 

American Samoa N/A N/A N/A N/A 

Commonwealth of the 

Northern Mariana 

Islands N/A N/A N/A N/A 

2002 Economic Census 

NAICS code: 712130 

D=Information withheld by Census to avoid disclosing data for individual companies 

a= 0-19 employees 

b= 20-99 employees 

c=100-249 employees 

e=250-499 employees 

f=500-999 employees 
M-4

Table 4: Summary of overall information on coastal food and lodging services 

State Number of 

Establishments 

Revenues and 

Receipts ($000’s)1

Annual Payroll 

($000’s)1

Number of Paid 

Employees1

Atlantic/Gulf of 

Mexico Region 

Alabama 956 713,581 202,919 18,299 

Connecticut 4,502 4,979,638 1,454,704 80,017 

Delaware 1,576 1,231,595 355,458 26,972 

Florida 23,742 20,991,636 5,847,116 460,330 

Georgia 1,113 1,040,073 300,917 24,583 

Louisiana 3,384 3,408,930 972,762 76,709 

Maine 2,446 1,346,224 393,600 25,814 

Maryland 5,139 4,322,393 1,189,482 95,547 

Massachusetts 8,572 7,172,834 2,103,016 139,707 

Mississippi 723 1,701,789 472,684 27,523 

North Carolina 1,626 997,181 277,497 26,059 

New Hampshire 751 498,076 152,805 10,857 

New Jersey 9,923 10,596,279 2,933,489 165,618 

New York 22,802 19,302,622 5,535,678 309,156 

Pennsylvania 4,045 2,742,606 734,949 54,681 

Rhode Island 2,701 1,731,799 502,394 38,573 

South Carolina 2,608 2,741,304 771,157 55,853 

Texas 9,002 7,626,398 2,100,395 178,631 

Virginia 2,695 2,125,937 556,374 52,167 

Puerto Rico 4,133 3,360,226 732,147 63,810 

Virgin Islands 313 331008 92,357 5,639 

Region Total 112,752 98,962,129 27,681,900 1,936,545 

 

Pacific Region 

Alaska 1,598 1,178,807 354,615 20,379 

California 45,609 40,169,743 11,522,595 800,742 

Oregon 1,909 1,058,286 305,453 25,221 

Washington 9,212 6,275,983 1,874,094 139,301 

Region Total 58,328 48,682,819 14,056,757 985,643 

 

Pacific Islands 

Region 

Hawaii 3,138 5,551,380 1,604,706 85,641 

Guam 392 629,672 168,623 11,199 

American Samoa 99 21,335 3,598 536 

Commonwealth of the 

Northern Mariana 

Islands 

151 197,187 47,275 4,304 

Region Total 3,780 6,399,574 1,824,202 101,680 

2002 Economic Census 

NAICS code: 72 (combined food and lodging industry category) 

1

The following coastal counties were excluded since information for these counties were withheld by the Census to 

avoid disclosing data for individual companies: Camden County, NC; Perquimans County, NC; Kenedy County, TX; 

Kleberg County, TX; Mathews County, VA; Surry County, VA; Aleutians East Borough, AK; Lake and Peninsula 

Borough, AK; Northwest Arctic Borough, AK; Wade Hampton Census Area, AK; and Kalawao County, HI. 
APPENDIX N 

DRAFT PEIS PUBLIC COMMENTS AND NMFS RESPONSES

WAI'I AT MANOA 

rvation Division 

atic Environmental Impact Statement that I 

on the issuance of the "Policies and Best Practices 

se, Rehabilitation and Release, and future 

I think that the permit is a fine idea and I also 

mit should be done correctly. I believe that the 

al Descriptions of Research Methodologies 

ires modification in its section 1.1.15 Auditory 

d Potential. 

 error to not include the mysticete cetaceans in the 

 can be measured using evoked potential 

revious Marine Mammal Permit issued to Dr. Sam 

oked Potentials to be measured on mysticete 

 of research now cuts off a very important and 

n on this group of animals. There is no apparent 

group of animals and they should he included in 

aring of whales using auditory evoked potentials. 

dicates that "sounds are presented through a 

 jaw". That method of sound presentation is not 

assured that bottlenosed dolphins hear well et a1 1999), many other species of odontocetes 

 One can be assured that sound is traveling 

nd that sound can be best measured in the free 

ter around the animal rather than through a 

to all odontocetes in all Auditory Evoked Potential 

ls should certainly not be limited to a "jawphone 

e lower jaw would also certainly not be the best 

sticete. 

t.. ."Recording, ground and reference suction cup 

e dorsal midline". That is also not necessary or 

water do not require a ground electrode. Only 

A suction cup electrode attached to the dorsal fin is 

ecure it with a suction cup. There is little 

n the dorsal fin. 

en examined hear frequencies from 1 to 160 kHz. 

e and the white beaked dolphin, hear as high as 180 

kHz (Nachtigall et al, 2000). Some mysticetes, because of the frequency of their 

emitted signals, are thought to hear as low as 20 Hz. The written range of 

"Frequencies used for testing range from 5 to 120 kHz" written in section 1.1.15 

severely, and unnecessarily, limits the hearing range tests of cetaceans. 

I believe that the Stranding Response Program should be permitting the testing of hearing 

of stranded cetaceans and other marine mammals by qualified and trained professionals. 

These tests both allow the measurement of new species and the diagnostic evaluation of the hearing of beached and stranded animals. This knowledge serves to benefit both the individual animals and their species. I do not believe that qualified scientists should be 

limited by the Auditory Evoked Potential guidelines currently presented in Section 

1.1.15. 

Sincerely, 

w 

Paul E. Nachtigall 

References 

Mshl, B., Ay W.W.L., Pawloski, J.L. and Nachtigall, P.E. (1999) Dolphin 

hearing: Relative sensitivity as a function of point of application of a contact 

sound source in the jaw and head region. Journal of the Acoustical Society of 

America. 105,3421-3424 

Nachtigall, P.E., Lemonds, D.W., and Roitblat, H. L. (2000) Psychoacoustic 

Studies of Whale and Dolphin Hearing. In: Au, W.W.L, Popper, A.N. and Fay 

R.J. (eds) Hearing By Whales, Springer-Verlag, New York pp. 330-364. 
THIS PAGE INTENTIONALLY LEFT BLANK 
THIS PAGE INTENTIONALLY LEFT BLANK 
Conservaaon Divislon 

m 13635 

National Aquarium in Baltimore (NAIB), addresses 

 Programmatic Environmental Impact Statement 

and Stranding Response Program PMHSRP). The 

onal hlarine Fisheries Senice (NMFS) to 

Issuance and implementation of the Policles and 

nding Response, Rehabhtauon, and Release 

not only a need, but also an obligauon to develop 

marine mammal stranding response, rehabdramon, 

'hr MhlHSRP provides a vltal service by 

rule mammals, as well as the collectton of samples 

ment and consenration of these species and their 

rogram (IvL4RP) of the National Aquarium in 

g thc PEIS public hearing in Silver Sprmg, MU, on 

nauves were presented. Following are specific 

ernauve. 

nse Preferred Alternative (A4): Under thzs 

l Stranding Agreement evaluation mtena. Strirnding 

basis to those entihes meeting the niteriu (mcluding nnewals 

t. New Strandtng Agreements would include current and 

uve for irnplemennng a Naaonal Template for 

. Our Marine Anunal Rescue Program has always 

excellent wntten protocols, and we fully support own operahons and Stranding Network goals. 

me of infoxmation required in the General 

ment renewal wdl take many weeks of dedicated 

s that rely on volunteer services, including ours, may 

@, be lfnable to achieve in the foreseeable future. We urge NMFS to develop a simpler process, 

part~cularl~ for Smanding Agreement renewals. Ode possibility would be to reduce the 

written component and rely more on NMFS inspeption teams to conduct onsite 

evaluations. It would be highly regrettable to implent a process so burdensome that it 

would impede the ability of network members in &od standmg to continue to participate in 

this important progmm. 

2. Carcass Disposal Preferred Alternative (B3) Under this alrematiw, Nh4FS wdd advocate 

the nmova/ ofcbemicuhj eathani?ed animal Canasses @sifejr dispoIal by inCinmtion, Ian&& or other 

methods, such nr mmposting. Anid that & nuhirally ori an eatbanivd by other means mq be dupsed 

of by whatew meansfemanb/e and aI(0wed 

The NAIB understands the potential nega ve impacts that chemically-euthanized 

carcasses may have on the natural environment an b other animals, and supporn the 

altemative to transport these carcasses off-site for disposal when possible. The NAIB also understands that eveq situation mvolving chemic -euthanized carcasses is unique (site 

location, size of animal, proximity to other feder protected lands/species, etc.), and that relocation of these carcasses is not always feasible. Incidents involviug large whales and 

mass strandings are particularly problematic: the v lume of euthanized animals can be pat and the costs of removal even greater. The costs r lated to carcass removal in such events 

strandings are common. 

7 

should be shared by local landowners or local/statb agencies. This would require advanced 

development of cost-sharing agreements with thesb parties, particulatly in areas where 

identtfy alternative disposal methods for non-eutwed carcasses. 3. Rehabilitation Activities 

continae the current rehabi/ifation 

rehabilitationfan'lities and modaa 

StanLnis would be ekmented 

The NAIB supports the Rehabilitation Facpty Standards and agrees that gwdelines 

for live animal response, rehabilita~on, and releaseshould be ditected by NMFS with input 

from regional strandmg coordinators and local Sqding Agreement holders. 

Public display of animals in rehabilitation should b investigated and defhed. The Marine 

Animal Rescue Program recognizes the value of p blic outreach on marine mammal health 

and stranding response. Ow: outreach efforts are d ore effective when the public can make a 

personal connection to an animal, especially one thbt strands due to a human-rekted injury 

(marine debris ingestion, boat saike injury, gunshot, etc.). We believe a middle ground can 
dty de? that d IOW public viewing with no 

porhuutle increase public awareness and support 

HSRP. 1 

e availabld for rehabilitation facilities, and we 

 John H. qescotf Marine Mammal Rescue 

ould be ayarded to organizations that seek to 

Preferred Nternative 03): Under this a/tmatiue, 

wities $the $randing nemrk, with the abihty to modz 

re m'teria +uki be impkmented 

entation ob the Release Critexia. However, there are 

he current release guidelines. The criteria for 

e, and pos rehabifitation release should be clarified, 

 of health assessment. Also, post-release 

aged or s ongly recommended when appropriate, 

uld be ma 1 e available. 

ed Alternative (E3): Under this altmativc, NMFS 

tanglement ~emrk, mfb the abi& to add newpard+& 

ologis, whed nemsary. Cmnt andfirtun Stranding 

kment ofpin $eds and mdcetaceans. Tk new 

uM authori c tk mnt andfirtun disentanglement 

st nehuork 1 uki continue their cumnt actides. 

t netwk toJ coomlinafe the sfructun and training with the 

idelines and trainingpnnq&esf.r network pad@ants 

entation of an effective and coordinated national 

g is essenti4l to improve human and animal safety. 

eceive basic disentanglement tramng for response 

anglement$. 

ities Prefqrred Alternative (E3): Under this 

es, Permits, conservation and Eahcation Division mu12 

mit that ~IIM include the mnt and future biomonitoring 

e of a new ermit for current and new research 

de an exce$nt oppo~nity to monitor not only 

health in gkneral 

ational Mapne Fisheries Service for giving members 

the opportunity to respond and comment on the 

d applaud 4e efforts put forth by MMHSRP staff to 

mpact Statement and would like to thank you for 

 process. qe have enjoyed being a member of the 

@, Northeast Region Strandmg Network for nearly 1 years, and look forward to continuing 

our cooperative relationship with the network and ! NMFS. 

Brent R %taker M.S., D.V.M. f Deputy Executive Director for Biological progr+ National Aquarium in Baltimore 1 

Jder Dittmar 

Stranding Coordinator 

Marine Animal Rescue Program 

National Aquatium in Baltimore 
No*h Slope Borough 

OFFICE OF THE MAYOR 

P.O. Box 69 

Barrow, Alaska 99723 

Phone: 907852-2611 or 0200 

Fax: 907 852-0337 or 2595 

email: edward.itta&orth-slope.org 

Edword S. Itttz. Mayor 

April 26,2007 

David Cottingham 

Chief 

Marine Mammal & Sea Turtle Conservation Division 

Office of Protected Resources 

National Marine Fisheries Service, NOAA 

1315 East-West Highway 

Silver Spring, MD 2091 0 

RE: Draft Programmatic Environmental Impact Statement for the Marine Mammal 

and Stranding Response Program 

Dear Mr. Cottiogham: 

The North Slope Borough appreciates this opporhmity to comment on the Draft 

Programmatic Environmental Impact Statement for the Marine Mammal and Stranding 

Response Program, specifically with respect to the sections pextainmg to the release of 

rehabilitated animals. The borough's Department of Wildlife Management more detailed 

comments are provided in an attachment to this letter. 

TheNorth SlopeBorough is in ageement with the Ice Seal Committee, the AlaskaNanuuq 

Commission and the Eskimo Walrus Commission in their opposition to activities that may 

be harmful to our residents or the subsistence wildlife on which we depend The 

reintroduction of rehabilitated marine mammals into the waters sunounding the borough 

conveys risks to our subsistence species though the possible introduction of transmissible 

wildlife diseases. Additionally, our residents could potentially be at risk if these diseases 

were zoonotic. 

We are highly dependent on our wildlife, both nutritionally and culturally. me positive 

effects of reintroducing one animal into our surrounding marine mammal populations are 

small to non-existeq while the risks are potentially very large. 

It is our desire that NOAA will address our concerns in its revised MMHSW SEE 

document. We would like NOAA to recognize these risks and make an exception to its 

reintroduction rule by prohibiting the reintroduction of rehabilitated marine mammals into 

subsistence populations of marine mammals. 

Again, thank you for the oppoi-tunity to comment and we appreciate your consideration of 

our request. For fuither information, please feel fiee to contact our Department of Wildlife 

Sincerely, 

Edward S. Itta 

Mayor 

cc: Taqulik Hepa, Director NSB Depmnt of Wildlife Management 

Johnny Aiken, Director NSB Planning Deparrment 

loe Seal Comrmss~on 

AlaslraNanuuq Comssion 

Eskimo Walrus Commission 

zoom YV~ OT:UO LOOZ/OC/PO coom YVd 0T:UO LOOZ/OC/PO 
"Released animal could cany a zoonotic disease and infect wildpopulation" (ES-lo). 

This ooint needs to address subsistence concerns (as does the EIS in eeneral). It also 

should be expanded to include both zoonotic and non-zoonotic diseases, as both could 

affect population status and the subsistmce users that consume reintroduced subsistence 

species or animals that come in contact with them. This concern is specific to Alaska. 

With respect to population effects: there are no known endangered pirmiped populations 

along the coasts of the North Slope Borough. The situation is similar for small cetaceans. 

It is reasonable to say that the reintroduction of one or even several rehabilitated animals 

into this region is unlikely to have a positive effect on the population status of a @en 

species. The point that we would like clarified in this document is that there are several 

potential negative effecm that may occur. 

Animals under rehabilitation are potentially exposed to pathogens (both common and 

novel) introduced into the facility by other sick animals from different geographic 

areaslspecies groups. Regardless of the amount of care taken to avoid this by the 

rehabilitation facility, the possibility exists. In addition, animals admitted to these 

facilities are generally ill and are subsequently subjected to the additional stress of 

captutc, transport and captivity. These additional stressors are likely to be 

immunosuppressive and therefore make the animal more susceptible to pathogens that it 

has previously been exposed to or carries, as well as pathogens it is "ndve" to. Stressinduced, sub~linical activation of pathogens may also occur. Latent pathogens may pose 

an important infectious disease risk to marine marnmals involved in rehabitation. The 

risk likely increases as the rehabilitation duration increases. Risks associated with most 

bacterial, fungal, viral, and parasitic pathogens can potentially be reduced by a suitable 

quarantine period before release and by appropriate medical care. However, latent viruses 

are unaffected by such actions. Immune stress resulting £rom captivity/transport/handliig 

may allow inoreased reactivation of viruses and may increase the incidence and duration 

of viral shedding. Suoh a result may increase the concentration of vituses in the 

rehabilitation facility environment, increasing the odds of transmission. 

Increased susceptibility to disease may have several consequences for the residents of the 

NSB. The subsistence culture is dependent upon these species for survival. Any pathosen 

that directly threatens or affects the population health of a given subsistence species, in 

turn, affects Che subsistence user. Population decline leadimg to decreased hunting success 

may be the most direct effect. Diseased or undesirable subsistence hunted animals unfit 

for consumption are other potential outcomes. Additionally, the species affected may not 

be the one reintroduced into the environment. A rehabilitated animal exposed to a 

pathogen (i.e., a viral disease), latent or non-latent, may function normally or adequately 

enough to allow for release. This pathogen may not affect this species directly, but may 

be transmitted to and have devastating effects on other speciff, that share habitat with this 

animal. 

Wd69:ZL LOOZ/OE/bO 

NORTH SLOPE BOROUGH 

Department of Wildlife Management P.O. Box 69 

Bmw, Alaska 99723 

Phone: Cenrral Office : (907) 852-261 1 350 or: (907) 8526350 

FAX: (907) 852 0351 or 8948 

Arctic Research Facility (907) 852-0352 

Taqulik R. Hepa, Director 

April 27,2007 

David Cottingbmn 

Chief 

Marine Mammal & Sea Turtle Conservation Division 

Office of Protected Resources 

National Marine Fisheries Service, NOAA 

1315 East-West Highway 

Silver Spring, MD 20910 

RE: Draft Programmatic Environmental Impact Statement for the Marine Mammal 

and Stranding Response Program 

Dear Mr. Cottingham: 

The North Slope Borough Department of Wildlife Management (NSB-DWM) wishes to 

comment on NOAA's Draft Programmatic Environmental Impact Statement for the 

Marine Mmgnal Health and Stranding Response Program, specifically with respect to the 

sections pertaining to the release of rehabilitated animals. 

The North Slope Borough Department of Wildlife Management facilitates sustainable 

harvests and monitors populations of fish and wildlife species through research, 

leadership, and advocacy from local to international levels. We specifically focus on 

subsistence species, including marine and terrestrial mammals, buds and fish. 

Subsistence species are &tical to the residents of the NSB, both culturally and 

nutritionally. We do not feel that the full range of potential adverse effects related to 

release of rehabilitated animak into subsistence species populations bas been adequately 

addressed in the EIS. 

As noted in the EIS, there are potential adverse effects associated with the release of 

rehabilitated animals back into the wild. The specific danger noted is: 

DOOW X6d 01:80 LOOZ/OC!tO 

Wd69:ZL LOOZ/OE/bO 

SOOF. YVd TT:U0 LOOZ/OC/PO 
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2

“accidental.” Entanglements will kill and injure large whales as long as we continue to fish with current techniques – it is no accident.

Entangled whales, even when they survive the initial risk of drowning, often

succumb to complications from their injuries or to starvation over time. These whales

may travel thousands of miles dragging gear with them and death can occur months or even years after becoming entangled. Emaciated whales sink quickly upon death. As a result, most large whale entanglement deaths go unreported and no reliable mortality statistics exist. The most credible estimates of large whale entanglement rates come from photographic analysis of the scars on whales that survive. Approximately 3 out of every 4 North Atlantic right whales and at least 1 out of every 2 humpback whales in the Gulf of Maine population bear scars from becoming entangled in fishing gear. At least 10% of both these populations will acquire new entanglement scars each year. Although the entanglement problem may be best documented along the Atlantic coast of North America, it is a world wide problem with numerous documented cases in U. S. Pacific waters of Hawaii, Alaska, and the continental states. 

Under the auspices of the MMHSRP, the Provincetown Center for Coastal Studies 

coordinates the emergency responses conducted by the Atlantic Large Whale Disentanglement Network (Network) that benefit the welfare of individual whales in

distress from entanglement and collects scientific information about the causes and effects of entanglement. For populations or species with extremely low numbers of individuals, such as the North Atlantic right whale, saving any females may help tip the balance toward survival rather than extinction. The Network disentangles ~72% of the entangled whales that well-trained and equipped disentanglement teams can actually get to on the water, giving those whales a better chance to heal, recover, and hopefully reproduce. Disentanglement activities conducted under the MMHSRP improve the scientific understanding of entanglement by providing opportunities to collect critical

data from affected animals.

Despite any benefits for individuals, disentanglement efforts should not be 

regarded as a long term conservation strategy to save endangered whale populations. It is important to understand that disentanglement cannot reverse injuries whales sustain during entanglement. These injuries are “takes” under the MMPA and may have healthand reproductive consequences for the whales. Furthermore, more than two decades of 

experience suggests that only a small fraction of whales that become entangled will be reported. This is because reports of entangled whales depend largely on seasonal research survey efforts and opportunistic sightings. Even when an entangled whale is seen and reported, it is sometimes impossible for disentanglement teams to respond because of the distance, weather, time of day, or other factors. The greatest benefits forwhale populations will ultimately rely on applying information gathered duringdisentanglement activities to designing and implementing effective regulations that prevent entanglements.

Until adequate take reduction measures are in place to achieve the Zero 

Mortality Rate Goal of the MMPA, disentanglement activities will remain an essential 
3

ss and to collect detailed documentation of all 

e health of animals involved. Disentanglement

 document that any take reduction measures 

 effect. Setting national standards and guidelines 

collecting quality data is a critical step in ensuring 

s safely as possible and the necessary data are 

a step in the right direction. This alternative allows

nders, and could benefit human safety by setting 

n techniques and encouraging development of new 

Better and more uniform training across the 

and the need and reasons for documenting 

nting a network structure for disentanglement 

hat now utilized in Atlantic waters off the East

iency, maximizing the benefits of these 

est use of limited resources for response.

hat disentangling large whales is very dangerous.

ry during 23 years of disentanglement activity is 

 protocols and extensive training of Network 

ties, and training criteria used by PCCS have been 

protocols and safety record have been built. A

ntanglement roles and training levels used by 

t the “Draft NMFS criteria for disentanglement 

the Interim Policies and Best Practices for Marine 

 Release section at the end of Appendix C. We

ational standards takes time and this draft is to be 

ent Guidelines”. We believe there is room for 

g levels set forth in this document.

, and criteria should be realistic if they are to be 

sentanglers states that they “must have the 

r equipment at the time of the event to conduct a 

hood of success.” The “likelihood of success” for

nds on a combination of many variables, such as 

behavior, and weather conditions, that are beyond 

The fact that “Primary Disentanglers must have 

roper equipment at the time of the event to conduct 

We recommend that the words “with a high 

4

There is no substitute for the give and take interactions that live training 

opportunities provide. PCCS encourages that two certified national training centers, one 

on the Atlantic coast and one on the Pacific coast, be established to accomplish the goal 

of implementing the national standards and guidelines. Having clearly designated certified training centers will greatly facilitate implementation of standardized training so that the full benefits to human safety of Alternative E3 can be realized. Training would not occur exclusively at these training centers; rather those conducting disentanglement training would come from the certified training centers. This model has proven to be very effective on the Atlantic coast where PCCS has hosted trainees in an apprenticeship program and also sent staff to train Network members at various locations.

The training video referred to in Level 1 and 2 criteria was created by PCCS 

specifically for distribution to U. S. Coast Guard stations to present Level 1 informationto Coast Guard personnel. While much of the information is still relevant and accurate, the video is somewhat dated. Viewing this video is not a substitute for on-water

experience or training and should be deleted as an “or” criteria listed for Level 2 certification.

Definition of criteria for certification should be improved. Requiring completion 

of Level 1, Level 2, and Level 3 classroom or on-water training without some indicationof the objectives of the training is vague. It should also be recognized that some people have extensive skills and experience that is applicable. We suggest the following objectives be incorporated to help clarify the criteria:

Level 1 • Level 1 classroom training covers definition of entanglement with examples, 

information on species usually involved, need for standby, documentation, overview of basic assessment and disentanglement objectives and techniques.

Level 2 • Documented whale experience or at-sea training, including species and individual 

ID, visual tracking (standing-by), disentanglement operation protocols, basic understanding of equipment (including telemetry), and disentanglement strategy.

Level 3• Demonstrated understanding of Network protocols and authorizations.• Demonstrated understanding of, and ability to use specialized tools including 

telemetry equipment.

• Demonstrated understanding of disentanglement strategies, planning, and 

techniques.

There are inconsistencies between the responsibilities and certification criteria for 

some of the Levels. For example, Level 2 personnel are tasked to “provide a thorough 

assessment of the nature of the entanglement and the species, condition and behavior of the whale”, but specific knowledge of species ID and behavior is not required until Level 

3 certification. The Level 2 criteria suggested above should help rectify this discrepancy. Level 3 personnel are critical to the success of Network response. In some areas they are the only Primary First Responders available. The stated objectives of training above will 
DEFINITIONS OF KEY DISENTANGLEMENT ROLES

AND TRAINING LEVELS

Provincetown Center for Coastal Studies

What follows is a set of definitions and guidelines for Network members that are applicable to the entire U.S. Atlantic Large Whale Disentanglement Network. Specific training curricula are not presented here. 

Levels of Participation in the Disentanglement Network - DefinitionsFirst Responder is a general term that is used to describe anyone in the Network with any level of training who may respond to an entanglement report under Network protocols and authorization. At a minimum a First Responder will voluntarily attempt to standby with an entangled whale and, depending on training, experience, authorization, and equipment available, may also assess and perhaps tag the 

whale. In certain cases individuals with higher Network responsibilities (Levels Three, Four, and Five) will serve as Primary First Responders in local areas. Primary First Responders are the principal local 

contacts for the Network. They typically organize efforts locally, have access to vessels and specialized equipment, and are on call full-time (may be seasonal). Primary First Responders may attempt disentanglements during first response only under certain conditions and authorization (described below).Any First Responder's anticipated range of tasks is generally dependent upon Network classification.Member classifications are determined on an individual basis using a variety and combination of factors including, but not limited to: 

• Preexisting experience and skills • Training• Opportunity and available resources • Location• Commitment and ability to respond as appropriate. 

Primary Disentanglers are individuals who can perform all of the responsibilities of a first responder,but who also meet the criteria used by NMFS for selecting individuals who may undertake the very dangerous activity of disentangling (i.e. attaching to an entanglement, stopping, and cutting a whale free).Primary Disentanglers must have the experience, training, support and proper equipment to conduct a full disentanglement with a high likelihood of success. Primary Disentanglers are those rated at Level 

Four and Five in the network.Authorization noteOnly PCCS holds blanket standing authority to conduct disentanglement activities along the U.S. Atlantic coastline under federal authorization; no blanket authority is granted to individual Network members.Therefore all activities that may require federal authorization must be done under the supervision and permission of the Provincetown Center for Coastal Studies.Personal riskAll responders are responsible for making their own judgment in regard to personal risk and must always work within their level of confidence regardless of its bearing on a mission’s outcome.Network Training and Response Levels
2

hose with prerequisite professional marine experience -

Officers, marine scientists)

nd/or second-hand knowledge of local entanglements 

reporting an entanglement and the Coast Guard with offer 

ould come from professional fishing, field biology, marine 

 

and provided contact information

nd participation

d stand-by, if requested

ent of first response (crowd control, contact info, etc.)

n, and assistance to Primary First Responders, as needed, 

d disentanglement operations on telemetry tagged whales 

a training, including species and individual ID, visual 

 operation protocols, basic understanding of equipment 

ment strategy.

 

ed to respond if conditions allow 

 local fishing industry, Coast Guard, and other resources.

ness plan (first response). 

mentation, recommendations during first response 

 needed and authorized 

ales, under supervision (phone or radio) of PCCS and only 

hale or when it is determined that waiting for a Primary 

and tagging is a poor option (low risk, high likelihood of 

3

• Directly assist primary disentanglers aboard inflatable during disentanglement operations if 

requested

Level 3 requirements

• Level 2 qualification • Demonstrated understanding of Network protocols and authorizations• Demonstrated understanding of, and ability to use, specialized tools, including telemetry 

equipment

• Demonstrated understanding of disentanglement strategy, planning, and technique • Direct experience in disentanglement under Network protocols (assisting, documenting, etc.)• Rapid access to tools and vessels, as available • Strategic location • Willing and committed to providing full-time on-call service (coverage may be shared among 

other local Level 3 members) 

• Determination of qualification by PCCS and NMFS based on, but not limited to, assessment of all 

of the above criteria 

• Insurance required, preferably through member's organization 

LEVEL 4 Level 4 responsibilities

Report, stand by, assess, document, attach a telemetry buoy, consult on an action planDirect on-site disentanglement operations of any whale, except right whales.

Commitment to Consultation to include:

o Immediate Consultation: when possible, use satellite/cell phones to bring in additional

expert ideas/experience while on scene with an entangled whale 

On a case by case basis after consultation certain cuts on entangled right whales may be permitted 

at level 4 if the proposed action is first approved by a Level 5 member and NMFS authority (Rowles).

Level 4 requirementsAll Level 3 qualifications plus advanced experience and proven competence

• Determination of qualification by PCCS and NMFS based on assessment of, but not limited to, all 

of the above criteria 

• Positive evaluation from NMFS using information provided by PCCS/Network Coordinators and 

documentation (e.g. video) 

LEVEL 5Targeted Individuals: Level 4 Responders Level 5 responsibilities

• All Level 4 responsibilities in response to all species including North Atlantic right whales• Commitment to Consultation to include:

o Immediate Consultation: when possible, use satellite/cell phones to bring in additional

expert ideas/experience while on scene with an entangled right whale 

• Action Plan consultation participant for active entangled whale cases along with NMFS managers

and other disentanglement, and whale experts.
4

experience under Network strategies and protocols

around right whales

ale disentanglement

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mmal and Sea Turtle Conservation Division

5 

tal Impact Statement on the Marine 

am 

 in the process; however, we have several 

ndations to submit. 

ed to list level 2 or lower level responders under 

 Network table. While it is important to have a list 

evels, for the sake of standardization (mirror the 

 level 3 and higher should be listed in this 

volved in the Marine Mammal Disentanglement 

ould be reversed to coincide with designations 

stem structure (lower numbers actually represent 

s). This is a minor point that might help integrate 

agencies’ ICS response efforts. 

at the following responders, along with their level 

Alaska Region: 

vel 3 * 

cier Bay National Park, Gustavus, AK – level 4 * 

ion, Petersburg, AK – level 3 * 

n, Petersburg, AK – level 3 * 

 Petersburg, AK – level 3 * 

a, AK – level 4 

 Petersburg, AK – level 4 

s. 

Within Appendix H, on page 6 (H-4) a description of the general disentanglement procedures for large whales should include at least the use of sea anchors and perhaps the drag of small boats, in addition to floats to slow, provide some control, and maintain at surface large whales during disentanglement efforts. This would better mirror what is written within the body of the DPEIS. The DPEIS has strong ramifications regarding marine mammal response efforts of the MMHSRP, and we appreciate the opportunity to comment.Sincerely, Edward Lyman Marine Mammal Response Manager Hawaiian Islands Humpback Whale National Marine Sanctuary 726 S. Kihei Rd Kihei, HI 96753 Cc: David Mattila, Research and Rescue Coordinator for HIHWNMS 

il what investigation should be undertaken 

has occurred nor how best to document it in dead 

eams mandated by the Marine Mammal Protedion 

 data to provide evidence of interactions that may 

es that are not monitored by observer coverage 

ly evidence of large cetacean interactions with 

mes from thorough necropsy. Some specificity 

dards for accurate determination and documentation 

ed mandates. The NMFS must assure that it 

at the standards of stranding response and 

nt to the important task laid out in portions of the 

nt 

e MMSHRP on marine mammals. Clearly, 

 a positive impact on marine mammals. There is a 

f the live-stranded small cetaceans, few are taken 

ew are released." The wording in this sentence 

her this sentence means to inform readers that, of 

cilities, very few are released; or whether it is 

tation facilities and, of the remainder who are not, 

re released alive from the beach where they 

 interpretations has implications that should be 

 

ties are released, then the NMFS program should 

r candidates being chosen, are facilities unable to 

ls, etc.) and remedy them. If it is the latter scenario 

ach and die or are euthanized if not taken into 

e that this too should be addressed. If the low 

stranded and likely ill animals, then this would 

ll cetaceans are mass strandings, then it is not clear 

ned to the ocean. Other countries (e.g., Australia 

cally good success rate of beach releases of mass 

discrepancy in successful beach releases should 

e the successful beach release rate for stranded 

at this is not simply due to a different 

mals (i.e., "an animal on the beach should be 

eleased from the beach in short order" versus "an 

ed to survive if released expeditiously"). 

3 

Comment. olTbc ESUS an MMSKRP DPEIS We would have appreciated a brief discussion of the likely reason for discrepancies in 

release of animals shown in charts depicting the fate of stranded pinnipeds and cetaceans shown in figures 3-2 and 3-3 of this chapter and in regional sections such as 3-4 and 3-5. 

There are virtually no releases of cetaceans shown. If this means that virtudly all 

stranded animals are euthanized, we question this approach. If the "released" portion of 

each column only refers to animals taken into facilities for rehabilitation and 

subsequently released, this should be made clear. Similarly, if the "yellow" portion of the 

bar showing "alive" stranded animals includes animals that were returned to the water from the beach and thus not counted as "released," then it should be so noted, with percentages provided in a separate color to help readers better determine a success rate 

for stranded animals. As noted in our comments above, if the tiny rate of "released" 

animals is in fact an indication that live stranded cetaceans are almost always euthanized, 

then is not the case elsewhere in the world at least for mass stranded animals. A 

discussion of the reason behind this phenomenon would be helpful and the guidelines presented in the appendix might provide guidance for improving this rate. 

Chapter 5 

Page 2 discusses procedures and safeguards for use of euthanasia including referring to 

the AVMA guidance. However, determining whether or not an animal should be 

euthanized becomes and individual decision. This decision can be guided by a 

philosophical underpinning which the NMFS needs to provide. For example, NMFS 

should provide general guidance on situations or types of animals who are clearly not 

good candidates for release and should be considered for euthanasia and/or when animals 

might be released from the beach rather than euthanizing them. This sort of guidance has 

been lacking and has led to situations in which animals that were clearly poor candidates 

for release were taken into rehabilitation facilities, necessitating the expenditure of resources for their ultimately unsuccessful care or to find placement for non-releasable 

animals. Contrarily, if most mass stranded small cetaceans are euthanized, as appears to be the case in the previous chapter, then the NMFS should give guidance as to when to 

give animals the "benefit of the doubt" prior to considering euthanizing them. It would 

be helpful if NMFS provided guidelines to this end (e.g., in the draft appendices) or 

provided directed training to holders of letters of authorization. 

Mitigation for tagging, described under this chapter's alternatives, as well as in the permit 

in Appendix G and H should include a stipulation that the tags being used should be the 

smallest and least intrusive available that has been proven effective to meet the purpose. 

Further, there should be a stipulation that if any death occurs during capture or tagging of 

animals, research should be halted pending review by experts as to the reason for the 

mortality and to recommend means of avoiding additional mortality. 

Chapter 6 Cumulative Impacts 

Section 6.1.1 and Table 6.1 discuss the possibility of amending regulations under the 

MA to allow public viewing of animals being rehabilitated. Although we understand 

4 
he DEIS, we would strongly oppose such a 

t has been in the past. Because captive display is a 

 be viewed by the public for a fee simply 

for the public to view even if an animal may be 

ee is charged, it is difficult to completely isolate the 

mals to noise, stress, habituation to excessive 

nsmission. Animals should only be viewed if seen 

ws facilities to play tapes of previously rehabilitated 

 Best Policies and Practices 

e that this document will address in some manner 

o return animals to their natural habitat if at all 

reatest extent possible from the stranding site (or 

n as soon as possible after rehabilitation. 

s under "B. 1. c" [acronym] shall tag any animals 

atural habit using.. ." should say "released." 

e stranded marine mammals" may be taken for 

ifically includes the following activities: 1. 

her NMFS approved rehabilitation facility with the 

 b. temporary placement in a scientific research 

ermits], c. for permanent disposition at an 

HIS "exhibitors" license after consultation with 

t disposition at an authod facility" does not 

hich was stated to relate to "rehabilitation and 

ease as we understand the concept of release (and 

) which implies release back to the wild. We are 

section on the appropriate disposition of stranded 

 taken &om the beach for display rather than 

y if they are from a species that is novel or 

ay facility. Clause "c" should be omitted from the 

 possibility of keeping stranded animals for 

ed elsewhere. 

is "conditionally non-releasable" (manatees only). 

ccur until page 5-22. Nowhere is it explained why 

appears unnecessary or else this category should 

CmMcnbi of The HSUS a MMSEKP WEtS apply to other species as well. The discussion in section 5 simply states that it's applicable when the animal has a condition that would threaten the well-be'q of the animal or wild populations, but may change over time. Why is this term not used for 

cetaceans and/or pinnipeds? Why cmly manatees. The DEIS should explain the unique 

circumstances that require this extra category here and in section 5. 

Page 2-2 and others have a discussion regarding determinations of suitability for release of animals in rehabilitation facilities. This page requests forwarding dissenting opinions 

.of assessment team members for animals deemed "conditionally releasable." This does 

not address the concern about facilities taking into rehabilitation animals with a very poor 

prognosis for release. Although page ES-3 discusses what to do with non-releasable animals (i.e. euthanize or send to public display) there is no discussion of how to prevent this outcome by choosing animals that are good candidates for rehabilitation. As we noted above, the NMFS should provide clearer guidance. Page 2-9 and following pages provide questions to guide the decision regarding 

suitability of animals for release. Similar questions should be provided elsewhere to 

guide a determination of the suitability of an animal for transfer hm the beach to a 

rehabilitation facility (versus eithw euthanasia or beach release). This can prevent 

situations that have arisen in the past with animals who are marginal or poor candidates 

being taken into facilities for rehabilitation. Similarly section 3 provides very specific 

guidance for evaluating the releasability of animals. There should be similar specificity as to what makes an animal a good candidate for removal to a rehabilitation facility 

(particularly in the case of small cetaceans). 

Page 5-2 defines "conditionally non-releasable as it applies to manatees. As we note 

above, there should be a discussion of why this category is unique to manatees,and not appropriate for other species. 

Appendix E General Description of Research Methodologies 

As we noted above in our comments on Chapter 5, conditions of the permit and 

mitigation measures should include a stipulation that tags should not be experimental in 

design, and should be of a design that is the smallest and least intrusive available that has 

been proven successful to achieve the purpose of the tagging. There should also be a 

stipulation that the death of any animal during capture and/or tagging should result in 

immediate halt to the activity pending review by experts and possible modification of 

procedures to prevent hture mortality. 

Section 2.1.3 states that use of auditoly evoked potential (AEP) studies on mysticetes is 

not permitted at this time. But it also states that "if mysticete procedures are approved 

within the timeframe of the permit (five years), the MMHSRP would use these to conduct 

research. All protocols would be provided to NMFS PRI for approval prior to any 

6 
s is mt entidy clear, bet at- the pennit to be 

ntial studies on mystitetes sfroutd be considered a 

quire publication of the inte.nt to amend the permit 

unity for the puMi to comment on the 

earch 

 

 vaccirurtion is not completed. The Natikmd 

t reviewers be allowed to review and comment on 

cedure. 

hr the ESiMbMPA Pwdt Apttlieatien 

cts of stranding response, other than the very 

e assume to be emergency stranding response. All 

e lumped together. We would expect to see greater 

ded, for example, estimates of the number of 

e (i.e., euthanasia) and numbers of animals 

o permanent captive display. 

S permit, we note in the tables provided that 50 

ject to study with a requested mortality of up to 3 

 for cetaceans, which seems high based on capture 

n studies by Mote Marine Lab in Sarasota Further 

equested mortality of 3. This represents a mortality 

ted for mortality under the Steller sea Lion EIS and 

s. These mortality rates should be explained. If they 

nsider the mortality rate allowed to other permit 

of their reporting of mortality. 

e would like to see it supplemented in the sections 

 stress, as stated in our general comments at the 

regulations will he necessary to ensure parity in 

tions and treatment of animals. We also believe that 

andards for research as non-governmental entities 

should also join other government agencies in 

lso believe that the Stranding Response portion of 

perative of returning mass stranded animals to the 

FS should provide more specific guidance as to 

es for facility-based rehabilitation to prevent on

n in who are poor candidates for release (e.g. infant 

e or hlminating disease processes) 

Caonenb &The ESUS em MMSERP DPEIS 

Thank you for the opportunity to comment of the Draft Programmatic Enviroamental 

Impact Statement for this very important NMFS program. 

Sharon B. Young 

Marine Issues Field Diector 
SH AND GAME 

P.O. BOX 11 5526 

E CONSERVATION JUNEAU, AK 998115526 PHONE: (907) 46.54790 

FM (907) 4856142 

nservation Division 

n the Draft Programmatic Environmental Impact 

nd Release of Marine Mammals" on behalf of the Alaska 

ne of any state and is surrounded by four oceans that 

ds, 17 species of cetaceans, as well as sea otters and 

portant to coastal Alaska Natives for food, clothin&boat 

ects. Although the State of Alaska has no formal 

of marine mammals it does have an obligation to the 

al populations and their ecosystems healthy. 

 on the DPEIS addressing the activities of the Marine 

Program (MMHSRP), which includes: the National 

Marine Mammal Disentanglement Program, the Marine 

ergency Response Program, the Marine Mammal 

 John H. Prescott Marine Mammal Rescue Assistance 

mal Tissue and Senun Bank, and the MMHSRP 

ommehts pertain specifically to the release of 

7-1 1) "Any pathogen with a rehabilitation "hospital" 

e into a novel organism (including those with drug 

ug resistant) disease which could then be inimduced into 

 of an infected animal following rehabilitation, 

 evaluated prior to release." Although the DEIS specifies 

ould include a "medical assessment with a hands-on 

nimal's complete history, diagnostic test results, and 

cautions can only minimize the risk, not eliminate it. 

 tests are not developed until the disease is known. Many 

Mr. David Cottingham Page 2 May 25,2007 

tests used for marine mammals are developed for domestic animal use and the effectiveness for 

marine mammals is not known. False negatives from theses tests are common. In considering the effects of the release of rehabilitated marine mammals on cultural resources 

(Section 4.4.4.3, pg 4-47) we believe you need to consider that the ability to obtain marine mammals for food, boat covers, rope, clothing, artwork, and cultural objects could be severely 

affected by the release of a rehabilitated marine mammal that canies an undetected disease or 

parasite that infects wild populations. 

In considering socioeconomics (Section 4.6.4.3, pg 4-61) we believe you need to consider the cost 

to families in coastal Alaska if they cannot obtain food from the marine mammal resources and must purchase it in local stores. Food costs are extremely high in remote villages due to fuel costs 

for air transportation. 

The benefit to releasing a small number of rehabilitated marine mammals into healthy Alaskan 

populations does not come close to outweighing the risk to Alaskans dependent on marine mammal 

resources. Due to the importance of marine mammals to residents of Alaska and the risk to the wild 

populations, we recommend that the release of any translocated marine mammal (i.e., one that has been transported and placed into captivity for any length of time) into marine waters adjacent to 

Alaska be prohibited. To the extent that marine mammals can be rehabilitated or assisted in situ and released, we have no objection. 

Please contact Dr. Robert Small (907-465-6167), ADF&G's marine mammal program leader, if you 

require further clarification. 

Matt Robus Director cc: R. Small - ADF&G Division of Wildlife Conservation 
RP Draft

w.edu>w.edu>, "Pabst, D. Ann" <pabsta@uncw.edu>

ion Division

tions for the MMHSR document. 

s identified by NMFS in this document. I am sorry that I was

more complete document, but even with the extension of

 you require any clarification or additional comments, please

rom the text. I wouldn’t want it to look like that is the final

dings in the SER.

hales and humpback strandings occur during the winter

t period described is six months long and therefore describes

5/29/2007 4:32 PM

half of the year. Additionally, there is evidence from a number of aerial survey efforts off the mid-Atlantic andSE Atlantic Bight (reference documents as contract reports to the SER) of right whales and especially younghumpbacks in the region from Sept to June. I would suggest some language like “southern component of theirhome range”.Why is there a specific section on “marine mammal population change” only for the Alaska region?4-8 Direct cardiac injection of euthanasia solution on sedated animals has proven to be effective and relativelysafe fro the responding team.4-13 It is worth mentioning that euthanised animals generally concentrate fluids in the heart, brain and liver (?).These organs could be removed and dealt with separately while the remainder of the carcass was then safe toburry.4-25 I would like to commend the statement regarding potential injury to entangled animals may be intentionalby responders. I believe strongly that we need to be developing more invasive techniques for working with lifethreatening entanglements. A small injury to the animal, say a quick tissue cut, should not stop teams fromgoing in and actually cutting heavily entangled animals. The faster gear can be cut loose, the better the potentialoutcome for the animal.SincerelyWAMWilliam McLellanBiology and Marine BiologyUNC Wilmington601 South College RoadWilmington, NC 28403mclellanw@uncw.edu910-962-7266 office910-962-4066 fax

2 of 2 5/29/2007 4:32 PMWA McLellan comments on MMHSRP Draft
1 

 Conservation Division 

MHSRP EIS) 

act Statement for the Marine Mammal Health and 

RP). 

onservation Society- North America (WDCS-NA), 

mments regarding the Programmatic Environmental 

mal Health and Stranding Response Program 

NMFS to pursue, standardize and implement 

ograms. We believe the stranding and 

e essential to the continued protection and 

recognize the need for standardized practices 

elieve there is a need, and there should be 

ed collection and assessment of data and 

e response, rescue and research techniques. 

 Alternatives 

andardizing the program and issuing Stranding 

sis, we believe that the Preferred Alternative (A4) 

osed. 

does not specify the need to respond to floating 

omments [submitted on February 28, 2006 

on the Notice of Intent to Prepare an EIS for the 

s, in its definition of “stranded” as any marine 

jurisdiction. Both humpback and right whales 

ted Potential Biological Removal rate (PBR) for 

© WDCS (NA) 2007 2 these species yet floating carcasses of these species are not always retrieved for necropsy. Carcasses of other species of large whales are even less likely to be retrieved and necropsied resulting in limited information on the causes of death of these species. We believe that NMFS must respond to reports of all floating large whales, regardless of whether external signs of human interaction are noted on the carcass, but having due regard to the operational conditions that may be limit or constrain such attempts. Vessel strikes are frequently determined by necropsy, and not by external signs of trauma and, according to Moore et al. 2004, post mortem examinations are necessary to ensure better understanding of mortalities that are due to human interaction. We believe that floating large whales should be retrieved and thoroughly necropsied with a draft necropsy report made available within 14 [working] days of when the carcass is examined. Because there are areas where beaching a carcass for necropsy is difficult, we recommend NMFS funds the research, design and construction of a number of mobile necropsy stations or barges. These would be located along the length of the east coast, with sufficient funding available to allow for the stations or barges to be utilized thus ensuring these data are collected in all US waters and our knowledge increased. Carcass Disposal Alternatives: We support Alternative B3 recommending that chemically euthanized carcasses are transported offsite. While this Alternative alleviates many of the concerns of bioaccumulation resulting from scavengers preying on carcasses, we also believe that NMFS must support research into methods of euthanasia which are both humane and 

environmentally safe. Rehabilitation Activities Alternatives: We generally support Alternative C3 which would implement improved Rehabilitation Facility Standards, but we also strongly believe that the NMFS must be clear that the primary objective of the SA holder is to release or refloat an animal immediately from the stranding site and moving a stranded animal into a rehabilitation facility is a last resort. We are concerned that animals may be taken into rehabilitation with the express intent of supplying a captive facility. Data presented by NMFS in this document appear to substantiate these concerns. For instance, section 3.2.2.6 states that “up to 50% of the rehabilitated seals and sea lions are released back into the environment” and “of the livestranded small cetaceans, few are taken into a rehabilitation facility and very few are released”. It is unclear as to what happens to the other 50% of pinnipeds that are not released- are they retained as captive animals, euthanized or die in rehab? Similarly, for cetaceans, it is unclear as to why “very few” are released. Figure 3-3, Cetacean Strandings Nationwide appears to demonstrate that there is a substantially higher number of cetaceans taken into rehab versus the number released. The document offers no 
3 

es it indicate what is the fate of those that are not 

hat, as stated in 4.6.3.3, the cost to facilities 

meet new standards may be significant, we do not 

ional funds can be raised by allowing these 

mals in rehabilitation. 

 would require the West Coast Disentanglement 

dards and techniques currently employed by the 

de the on-going monitoring of animals through 

ction 4.2.5, NMFS indicates that “North Atlantic 

 if disentanglement efforts ceased, as 

ficant source of mortality”. While we support the 

upport the notion that this is an appropriate solution 

anglement is, at best, a stop-gap measure and 

 appropriate mitigation when other risk mitigation 

r a number of years. 

ies Alternatives 

pears the most appropriate, we believe that the 

tions should be minimized and suggest that NMFS 

unused portions of tissue, fecal matter, exhalation, 

orks. Future permit requests requiring these types 

e archived materials prior to authorization of 

hould be checked for signs of human interaction, it 

d/or depleted stocks be thoroughly examined for 

psy rather than external examination only). 

EIS 

st Region- Human Interaction, the PEIS notes ship 

species. While the issue of ship strikes is a 

otential demise of the critically endangered North 

pecies are at risk. 

© WDCS (NA) 2007 4 In the subsection, Northeast Region- Temporal Changes, it states that “ship strikes and entanglements are frequent in summer”. While we do not dispute the accuracy of this statement, we do question why documented entanglements and ship strikes that occur outside of summer are not considered, and have been excluded. Documenting human interaction throughout the year is critical in determining whether seasonal exemptions, as proposed in management schemes, are sufficient or appropriate. Conclusion We appreciate efforts by NMFS to increase standards throughout the Marine Mammal Health and Stranding Response Program. While we largely support the Proposed Alternatives within the PEIS, we believe that the document does not sufficiently consider response to reported individual animals from strategic/depleted stocks. Additionally it must increase mandates for thorough examination of carcasses for human interaction. We thank you for the opportunity to comment and for your time and consideration. Sincerely, 

Regina A. Asmutis-Silvia Biologist Whale and Dolphin Conservation Society 3 Jacqueline Lane Plymouth, MA 02360 508-830-1977 regina.asmutis-silvia@wdcs.org

Moore, MJ, AR Knowlton, SD Kraus, WA McLellan, and RK Bonde. 2004. Morphomentry, gross morphology and available histopathology in North Atlantic right whale (Eubalaena glacialis) mortalities (1970-2002). J. Cetacean Res. Manage. 6(3):199-214. 
e.md.us>

MD DNR) is authorized to respond to all dead stranded marine

tection Act. MD DNR's Marine Mammal and Sea Turtle Stranding

onse efforts since 1990 and is located at the Cooperative Oxford

The purpose of this letter is to comment upon the Draft

PEIS) on the activities of the Marine Mammal Health and Stranding

has the following comments.

While the participant organization is responsible for most costs

bility is unfair and impractical in the case of an Unusual Mortality

a UME and shipping costs to diagnostic labs can be an

not may, support costs associated with UMEs, particularly supplies

ey should be set aside to provide monetary support for UMEs

grant could cover additional costs associated with a UME. 

: If NMFS is going to implement the ICS structure in certain

ding organization to follow that structure, then NMFS needs to

 The need for completed data such as Level A form is imperative,

ta are due is a cause for concern. A set schedule suggests rigidity

s that have limited available personal or mitigating circumstances. It

 if this inflexible schedule is not met. 

act NMFS [Region] Regional Stranding Coordinator when there is a

ected unusual mortalities, extralimital or out of habitat situations,

strandings, and any other involving endangered or threatened

 very time constraining. Many facilities within the region get several

huge additional time commitment to those facilities to report each of

nteraction cases, within 24 hours. A larger time interval for this

s well as the importance of this information (does NMFS need to

 that information will be submitted through the National Database

entered in Level A data forms and other stranding/necropsy data

s information seems to be double duty for the responder(s). 

nal information, expedited reports (written and or verbal) of Level B

psy reports within 24 hours is also another time restrictive issue. It is

mpleted reports and analytical data within 24 hours of the

within 24 hours of a stranding is a concern especially for smaller

ces or for organizations that are inclined to have several animals

s. It often takes weeks, if not months, to get analytical results,

ransfer of any parts of marine mammals is filled out under the

ata sheet. It is redundant to also have to report this information to

n 30 days of the stranding(s) 

, part 2: Is NFMS going to provide required equipment lists that

vel A data? It is a concern that facilities may be penalized for not

t the NER facilities and organizations differ in size, number of staff

nd variety of species of animals that strand. As a result the

ne area may differ from another. 

7/10/2007 2:58 PM

On behalf of MD DNR, thank you for the opportunity to comment on this document. If you have any questions or needclarification about any of the comments provided above, please contact Lauren Shilling at lshilling@dnr.state.md.us or

Tricia Kimmel at tkimmel@dnr.state.md.us. We can also be reached at 410-226-5193. 

Sincerely,Lauren Shilling and Tricia Kimmel

Lauren N. ShillingMarine Mammal and Sea Turtle Stranding CoordinatorCooperative Oxford Lab904 South Morris St.Oxford, MD 21654Phone: (410) 226-5193 x. 132Stranding Pager: (410) 819-9426Fax: (410) 226-0120lshilling@dnr.state.md.us

2 of 2 7/10/2007 2:58 PMATTN: MMHSRP PEIS
P.O. Box 1329, Seward, AK 99664 

Fax (907) 224-6360 

Telephone 1-800.224-2525 OR (907) 224-6300 

To: NMFS 

AH": MMHSRP PElS From: Annie Madsen. Husbandry Assistant 

Fax: 301427-2584 Phone: 907.224.6358 

- 

Re: EIS for MMHSRP Comments 

Urgent For Review Please Comment Please Reply Please Recycle 

Comments: 

Please contact Carrie Goertz at 907-224-6326 or Lee Kelar at 907-224-6364 if you have questions w 

reaure further information. 

9072246380 ASC Exe~~ltlve 12 39 09 p In 06 30 ZOO7 2 110 

Alaska SeaLife Centere 

May 30,2007 

David Cottingham 

Chief, Marine Manmal and Sea Turtle Conservation Division 

Office of Protected Resources 

National Marine Fisheries Service 

1315 East-West Highway, Room 13635 

Silvcr Spring, MD 2091 0 

Dear Mr. Cottingham, 

Thank you very much for the opportunity to comment on the Environmental hnpact 

Statement (EIS) on the Marine Mammal Health and Stranding Response Program 

(MMHSRP). Attachcd, please find a list of comments. 

If you have questions regarding this document, please contact Carrie Goertz, Associate 

Veterinarian and Stranding Program Manager or myself at 907-224-6364. 

R. Lee Kellar 

Husbandry Director 

101 Ramlwvy A~crluo . P 0. Bun 1329 - Seward, Ala5lca 99664 

Phone (9071 >Ld~b3011 - Fnr (9117, 221~6320 

www nlarkr~e.zlrl<.urp 

05/30/2007 5:32PM 
Environmental Impacf Statenlent (EIS) on the Marine Mammal Health and Stranding Rcsponsc Program 

(MMHSRP) Comments 

National Template Comments: 

Having an strandtug agreement number would make it easier to reference. or please spcif)? hour this agreement 

should be referenced. 

Having an abbreviated ( I page) version to present when hansportmg animals would be helpful. 

Paee 5, Section B. 

Adclitioml bullet fo~ NMFS responsibility to read: 9. Coordinate re~onal acli~ities !a ensure appropriatc div~sio~i of 

responsibilities based on geography as well as mstitutional rcsponsibiliticr. 

Page 5, Section C. 

What should an organization do if financial constraints require limiting its efforts? Financial difficulties can come 

up qu~te suddenly and may not permit the requested not~fication time for changing the agreement. 

Is an organi7atinn rtlll allowed to request payment fox reasonable recovery costs for samples tramfsrrcd to 

aulhotiued persons or labs? 

Page 10. Section B.. Number 2. Bullet (c.1 

In regards to bullct point (e.), form or instructions should be provided by the NMFS ottice. 

Paec 11. Section A., Number 1. Bullet (b.l& (c.1 

In regards to bullet point (b.), it is recommended that AVID chips and satellite tags be added to th~s list. 

In regards to bullet point (c.), there 1s a formatting problem within the paragraph. 

Page 13, Section R.. Numher 1. Bullet (c.1 

h~ regards to bullet point (c.), it n recomn~c~~dcd that AVW chips and satellite tags be added to th~s list. 

Puce 16, Section A.. Number 3 

In rcgards to number 3, it is recommended that AVm chips and satellite tags be added tn this list. 

Paee 18. Section R.. Nnmher 1. Bullet if.) 

In regards to bullet point (f), we object to a blarrketprohibition as public display is possible ~thout impacting the 

rehabilitation of these animals Language used in another document conccrrung distance viewing with no inlpact is 

preferred. 

Page 18. Sectiuu B., Number 2, Bullet (aJ 

In ~egnrds to bullet poii~t (a,), profcssionnl Hwbandry staff IS ill a better pos~tion to assess the behav~oral rcadmess 

and should cithcr also sign or coordinate with thc rclcase determination paperwork. 

Evaluation Criteria Comments: 

Word choice sometimes implies requirements for 'new' applicants only, but doesn't always spcclfy. Please clarify 

d~fferences between new a~~d existmg organizations throughout lhe document. 

Page 2-1. Section 2.1. Number 2. 

Organizations will need time to develop thc documcntation dcscribed in 2.1 2. It would be best d the agency umld 

provide examples or templates to work off of. Alternatively, could the organizational summary uuscd for Prcscott 

Grant applications suffice? Perhaps the requirements for both th~s document and the organizational sumnmy for 

Prescntt grants applicanon be unitied. 

Page 2-1, Section 2.1, Nun~ber 3.. Bullet (a.) & (b.1 

Bullet (a.) should read. Brief sununary of the exlstl~~g or proposed scope ol'lhe stranding progrdm(e.g., all specles 

of cetaceans, pimipeds), and whether the requesl is for response to dead anunals only, live and dead mnlals, and/or 

rehabilitation. 

Rullct (b.] should read: Justification and dcscripbon of thc cxistmg or proposed geographic area of coverage and 

why the area of response is appropnate for the organization (e.g., the amount ofpersomeL~volunteerz and resources 

available, relative to rhoreline covered, 

Page 2-2. Section 2.1. Number 5. 

It would be helpful if NMFS could generate a complete list of items and the level of detail ("102 1" x 19F needles" 

or "a supply ul'varioua sized needles'' or evenjusl msc, samphg supplies) they are luterested m. Otherwise. 

organizations may not cover what the agency is looking for. Again, an example or template would hclp. 

Page 2-3, Scction 2.1, Number 8. & 9. 

In regards to number 8, resumes are also required under 2.1 4. h. Pick one place to cover this requirement. 

In regards to number 9, this should apply to new Standing Agreements only. 

Paee 2-3, Sectian 2.2 

The first paragraph should read: IiMFS will evaluate exiating and prospective participants based on their 

demonstrated kack record and their capabilities in the follou~ing areas as described in their request. 

Paee3-1, Section 3.1, Number 1. 

In regards to numbcr 1; what IS thc difference between representative and responder'? 

Page 4-2. Section 4.2, Number 3. 

The paragraph should read: The prospectwe Participant should demonstrate howledge of national, state, and local 

law5 relatlng lo live animal respolae. 

Page 5-1. Section 5.1. Number I..BuUet la.). Sub-bullet (iii.1 

The inaximum holding capacity dcpcnds upon thc specics. For facilities that receive a number of different species 

and have flexible holding options, how would the agency determine max capac~ty? For example. a facllity mght 

have a pool tha1 can hold scvcral smll anunals (i.e. harbor seals) but only a couple large animals (1.e. Steller sea 

hons). Also, somc organizations are llnuted more by staff and not space, how will YMFS take this into account? 

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05/30/2007 5:32PM 
Page 5-1, Section 5.1, Number l..Bullet (b.), Sub-bullet (ii.1 

[he sentence should lead: Human health and safety throughuut the rehabilitation facil~ty. 

Pdge 6-1. Section 6 

What is the policy for when the agency is propos~ng a designee fol an existing organization? 

Standards for Rehabilitation Facilities Comments: 

Page 2-1. Section 2.1. Paraera~h 4

The last sentence reads Pinnipeds with evidence of infectious disease must be quarantined (See Sections 2.4 

Quarantine). 

Does this mean that Pinn~peds with infectious diseases should be quarautmes fiom other rehabilitating 

animals? How many isolation areas is expecled? 

Paee 2-3. Section 2.1.2, 3'd BuUct Point 

Sentence should read: The tacihty must havc a plan to mauagc adult malcs. 

Pane 24, Section 2.1.5 

Palagraph should read: Animals housed at rehabilitation facilities muqt he prnvided with shelter to provide rehge 

from exkeme heat or cold. Pinnipeds held in rehabilitation facilities may not have l~ormal activity levels and thin 

atnmals may be unable to thennoregulate properly. These animals mny require shade structures to protecl them 

from direct sunlight and exkme heat, or shelter to protect them fromcold tcmpcraturcs or inclcmcnt wcathc~. 

Animals hcld in indoor facilities should be provided ulth appropriate light and dark photoperiods which mimic 

actual seasonal cond~tions. Except du~ing the pre-release conditioning phase, ensure adequate refugc hm cxucmcs. 

Pacc 2-5. Seetion 2.1.7.4"Bullet Point 

Is the stn~cture referenced in the paragraph meant to be a separate bmlding? Or can it he sqarate ronmsholdlng 

areas that prevent exchange of water and bod~ly fluids as well as prevent 'nose-to-nose' contact with other animals? 

This requirement is stricter than the requirement listed on pagc 2-15. 

Paee 2-7. Seclion 2.1 .lo, 1" Bullet Point 

Addition of the following sentence: Dependant pups are more labor intensive and requlrc more staffmg. 

Pare 2-10. Section 2.2.1. 2"d Bullet Point 

Sentence should read: Dram water from pools as often as necessarq. to kcep the pool waler quality within acceptable 

limits. 

Pane 2-12, Section 2.3.2.1"Bullel Point 

Sentcncc rcads: Measure water tempenlure. pH, salinity (if applicable), chemical additives (ti applicable) daily in 

all pools. 

Does this apply to open flow through systems with natural sca water? 

Page 2-15, Scction 2.4.1.1"~ullet Point & 51h Bullet Point 

9072246360 AbC Executve 12 40 26 p 111 06 30 2007 6r10 

05/30/2007 5:32PM 

In regards to thc Is bullet point, the usc of dividers, tarps, or physical space is very different from the shucturally 

separate facil~ty referenced on page 2-5. The description listed here is much more reasonahlc. 

9072246380 ASC Exe~~ltlve 12 40 56 p m 06 30 ZOO7 6 110 

05/30/2007 5:32PM 

In regards to the 5" bullet pomr. the sentence should read Malntain equiulpment and tools strictly ded~cated to the 

quarantine areas or thornugh ddisinfect~on. 

Paee 2-21. Section 2.6.1. 3rd Bullet Point 

In regards to the 3" bullet point, it is excesswe for a public display aquarium to have a nutritiolnst on staff. 

Pace 2-23. Section 2.7.1, sLh ~nllct Point 

Sentence reads. Have contingency plan for vetennary backup 

This should be the responsibillly of the facillty and not the veterinanan who may be a volunteer 

Paee 2-25. Section 2.7.2, 6th Bullet Point & Reuorts Bullets 

It is uot appropriate to assign hunlan health plans to thc vctcrinarian. A human hcalthplau sl~ould be developcd by 

the Hmn Resource pewomel with the help of a human medical professional. This should & the responsibility of 

thc facility, not the veterinanan 

Thc follow~ng rcpnm should hc thc refiponsibillty nf thc faclllty and not the vetennanan: 

Health and Safety Plan reviews 

Animal acquisitions and dispns~nons 

h'0.44 Form 89864,0MBP0648-0178 (Level A data) 

KOAA Fom~ 89878,OMB#0648-0178 (Marine Mammal Rel~dbilitdtion Dispus~t~on Report) 

Paee 2-26. Section 2.8.10'bullet Point 

Sentence reads: Serological assays may only go lo labs chat have validated bsts approved by NMFS, especially for 

release decisions or detcrminatlons. 

What does validation constitute'! What labs are thexe'! Will NMPS keep up with validatloris? 

Paee 2-30, Section 2.13 

The verblag in this paragraph differs from what is in the Stranding Agreement Template. This is a bdter version. 
Pace 4-5, Number 5. 

in rsgards to the first sentence, you night waut to more precisely define bite to specify breaking of skin. "Bites" 

ma), occrrr wlthout a breach of protective gear. Also, when tubmg an arlimal," bites" may occur wtthout bleach of 

protective gcal. 

In regards to rabics among pinnipeds, there is only one documented case. 

Paee 4-5, Number 6. 

This sentence is confusing. Perhaps more detall can be added. 

Paee 4-5. Number 7, 

We assume thar just bwause an animal was at 2 places, does not mean ~t ~sn't releasable. 

Paee 4-9. Scction 4.6. znd Parderaoh 

In the fust sentence, l~st desired parameters. What docs Chcm-12 include? Also ln the first sentence, delete blow 

hole as a sampling site for pinnipeds. 

In the third sentence, 3ml of Semm is recommended but another document recommends Iml per draw Please 

clarify. 

Pace 4-10. Sectlon 4.7 

Recomnlcnd smcnuing hs checklist as a stand alone documen1 for greater usabilit).. Rcconuncnd kccping it < 2 

pages and reduce font size as needed. 

Pagc 4-11. Scction 4.7 

New Point. History: The environmental couditmons are considered acceptable (e.g. prey avalIable, no hngenng 

contamination). 

7. Please defme 'bite" some&,here. 

17. Is this the release determination exam? Don't you haw to submit release paperwork 2 week prior? 

19. Is this the exam to be do~mc within 72 hours of rclcasc? 17 and 19 seem tn overlap. 

22. Change visual to in vision. 

25. 3mI total or each'? iiotc, clscwhcre th~s document mentions Iml per blood draw and that only 2 blood 

draws are requmred. 

New Point, Medical Clearance: Ihe veterinarian has recnred and reviewed all records on this ~NIII~~ from other 

facilities that held this animal. 

Appendix E 

Explain how the agency will keep this list and testing requirements up to date au lhat facilitics can easily stay 

informed. 

Appendix G 

Some formatting issues took place after Append~x G. Unclear of the titles of some pages. 

9072246360 ASC Executve 12 41 14 p 111 06~30-2007 7 ;I 0 

Standards for Release Comments: 

NMFS & USFWS should take into account the recommendations of the shanding facility and the AZA 'Taxon 

.4dsisor or Studbook Keeper for the specles before maklng a decision as to placement. 

Paee 2-9. Section 2.4. Number 1 

When taking an animals lustomy, docs mouthing qualify as a bitc or does the nard bite pertain to an animal breaking 

the ski11 of a human? 

Paee 2-12. Section 2d. Number 4.5" Paragraph 

The tlnrd sentence of this paragraph refers to microbial culture. Other than the obvious wound?, what would the 

'routmne' samples come Crum? Fecal? Nasal? 

Pagc 2-13, Section 2.4. Number 5.. Bullet (1.1 

The puagaph shuuld read: 

Required Identificalion Prior to Release. Marine mammals mnst be marked prior lo release lor individual 

idcntmiicat~on m thc wild (see 50 CEX Sec 216.27 (a)@) for specles under NMFS jurisdiction). Examples of preapproved ~dentificahon systcms includc flipper roto tags, ilippcr All-Flcx tags, Flippn Templc tags, passlvc 

integrated tramponder tags (PIT tags) radio tags, and freeze branding (Geraci and Loundsbur). 2005). (Satellite tags 

should be inrlr~ded in this list.) Insasive procedures such as.. .should be done under the direct supervision of the 

attending vetermanan and m1I need prior approval from NMFS and FWS and may require a monmtoring per~od 

followillg the procedure. Proper photo identification can also be considered parr of this protocol. Standard 

lndentification protocols exist lor various groups of mine ma~nmals that detai1 tlie methods and procedures for 

marhng Cot Cuturc idcnt~ficat~on mthe wild, and are included in the appropriate section for each taxononuc group. 

Contact the Agency strandmg cuordilliliur for more direction on lagging. 

Paee 2-14. Section 2.4. Number 5.. Bullet Ih.1 

First preference is releasmng the animal in the same generallgeograph~cal area where the an~mal war stranded. Thc 

second choice. especially ~f the annnal was shanded outslde of its normal range, 1s to release the ammal closer to or 

within 11s normal range, This is implied later but should probably also be referenced here. 

NOTE: Section 4.3 beginning on page 44 is formatted differently than 4.4,45 and 4.6, using the number 

suhsections that more or less correspond to the checklist. 4.5's Rehavinral subsections are given paragraph 

numbers. Recnmmend you standardize the style. 

The organization fur section 4.3 slkould mesh with the checklist preseuted later iu the document. Each polnt 

on Ule checklist should be described hcrc and each point hcre shodd have a corresponding question on the 

checklist. 

Paee 4-5, Number 4. 

The last sentence should read: Consultation with NMPS or FWS is thus required for pimipeck that have a knuwn 

l~iriory of exposure to terrestrial animals. 

Note: Yuu can never know for sure wkdt happcned belorc an animal was leported and brought in. 

05/30/2007 5:32PM 

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05/30/2007 5:32PM 
Appendix H 

This appcndix could use an up front description~summa~y of hov this infurmalion should be used in the slrandinp 

context ((verses the research context). 

At polnts this document seems to refer only to one taxon or species in many places wlthout specifying which and 

Uien does not discuss the other taxdspecies. Bonom-line, it is not alwa)+s clearu~lut species is being il~cluded and if 

all other species are excluded. 

Appendix H. paee H-1. Section 1.1.2 & 1.1.3 

Sections 1.1.2 and 1.1.3 are not typical activities for a shanding organization. 

Appendix H. pate H-2. Sextion 1.1.4 

The Cis1 senlence reads: 

Capture of marine rnaznmals my be necessary during research activities to collcct spccimens, perform an 

exanination, or attach tags or scientific instruments. 

This appendix should address stranding scenarios, not research, or there should be a preamble to discuss how it 

applies in stranding situations 

Appendix H, pate H-4. Section 1.1.4 

Chemical resttaint should require veterinary input. 

Appendix H, vage H-5. Section 1.1.5 

Sedahon of large pinnipeds should require vetennary mput. 

Appendix H. pace H-7, Section 1.1.6 

Insmments should be athched to the coat of an animal, not to the skin. 

Awendix H, page H-8. Sectinn 1.1.7 

Restrictions concerning hot branding should be specifically addressed. 

Appendix H. Dace H-10. Section 1.1.9 

Tlie second parapph refers to dolphin biopsy sites. What about other cetaceans and pinmpcds'? 

Appendix H. page 810, Swtion 1.1.10 

Some folks prefer 19G or even 20G, some prefer butterflies to straight needles. A4cmneedle is longer that needed 

for some sitedanimals and maybe too short in some cases. Recommend hs be changed lu rrad 'of appropriate 

size.' 

AppendlxH. page H-11. Section 1.1.10 

Again, I would lcavc tlic preclse needle sizr: up lo lhe discret~on of the veteriua~~n. nie extradural vcsscl 1s not a 

san~plmng site in otariids. Olariids and solnc plocids can be sampled from flipper neb veins. 

Aprcndix H, page H-12. Scction 1.1.13 

The second paragraph refers to extracting the ti15 tooth of the lower jaw What specles is this for? Pre-molars are 

extracted in pinn~peds 

Appendix H. rage H-13. Section 1.1.13 

Cathokrization is alsu possible m pinnipeds. 

The fourth paragraphs last sentence roads: Thc samples are sent to a diagnostic laboratory for culturing and species 

identification. 

Does specics rctc~ to thc parasltc spccies? Prey analysis7 

ADDendis H. pace H-14. Section 1.1.13 

Please site the source of the thermal probes. There are odier deep ~ectal probes available. 

In tbe last paragraph of Section 1.1.13, cllange brevetoxrn to any toxin 

Appendix 11, paee 11-14, Section 1.1.14 

Vetermanan ~nvolvement should be requ~red 

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05/30/2007 5:32PM 
05/30/2007 18:43 FAX 301 504 0099 MARINE PAPM.4L COMM. Q00l 

. -- .- . . 

MARINE COMMISSION 

4340 EAST-WEST m., RM. 905 

BJ3TmsDA, IVID 20814 

Telephone: 001) SM-0087 

Facsimiie: (3011 3M-0099 

FACSIMILE TRANSMISSION 

Dare: -30 

Total pap including coves 7 

Comments: &,h7&@ &z!&ffG@. 

05/30/200i 18:43 F.AX 301 501 0099 MARINE MAMMAL COPM. lm002 

MARINE MAMMAL COMMISSION 

4940 t4ST-WEST HIGHWAY, ROOM 905 

BETHESDA, MD 20814-4447 

Mr. David Cottingham 

Chief, Marine Mammal and Sea Turtle 

Consmaon Division 

Office OF Protected Resolvces 

Nationd &Lane Fisheries SeMrc 

1315 Eart-West Nghwap 

Silver Spring, A& MD 20910 

Deu Mr. C 

The MadneMammal Commssion, in consultationMth ic; Commrttee of Scientific Advisors 

on Marine Mammals, has reviewed thc Draft Programmatic Environmental Impact Statement 

(DPEIS) on the Natlonal Oceanic and Atmospheric Admhstnhon's Madnc Mammal Health and 

Saanding Response Progam (MMHSRP) with rcgard to the goals, policies, and requirements of the 

Mnrine Mammal Protection Act and he Nationd F,nwonmeutal Policy Art. We offcr the foUounng 

cornmalts and rccommendntlons. 

RECOMMENDATIONS 

The Madne Mammal Comsslon recommend$ that the National Mk Fisheties SeMce 

revise the DPEIS tprovide sn update on the starus of hal rcpom of unusual morraliry events, explore ways to 

promote completion and circulation of hal reports mom promptly, and ~denbfy actions rhar 

the Service can take to Lnprwe the sptheas and use of data fmmunusualmo&~ events; 

discurs the ctitena that the Service intends to use in its rwim and appro& or d~szpp~ovd 

of recommended releases of mhc miilm~ls, and plans for such rclesses, by rehabdbtion 

faulities; 

idcndfy the types of mformation that would bc included in prorocols for monitorhg released 

aim J, 

. specifp actions t'r the Seroicc plans to take to ensure that rchabilitntion fachties are m comphncr with the Intetim Standards for Kehabilitation Faulities; 

elaborate on the Seroice's plans for developing draft guidelines to govsn when public 

&splay of he mammals undergoing rehabilitation .will bc authorized, indudiug 

oppornwities for thc Com~msslon, the affecred facilities, and the public to review the draft 

- midelincs bcfore their adootion: . and 

discuss alternatives for addressing overcromdq at rehabilitation facihties, issues associated 

with the ulaccmcnt of non-tclealeasable marine m;rmnulr m oublic msolav facilities. and ctitctk 

for mahg obsite evaluations of rhe likelillilood +hat R stranded madne mamml can be 

successfly rehabilitated and released. 

PHONE: (301 ) 504-0067 PRINIEO ON BECYSLEO PAPER 05/30/2007 6:47PM 99 
05!30/2007 18:44 FAT 301 504 0099 MARINE NANWLL COMll. BOO3 

Mr. David Cothgham 

30 May 2007 

Page 2 

RATIONALE 

The MNISRP has been instrumental in coordinadng responses to stranding events 

narionwide, providmg care f01 suanded make mammals, and examining catcaeres and tissue 

samples to collect backgmund information on the possible causes of morbtdity and rnody. The 

M-c Mammal Commisuon cm the Scrvice and stranding network pardcipanh for these 

efforts. Tbc Cnmmission also commends the Service for its efforts in developing the DPEIS, which 

we genedy b&ve ptomdes 1 thorough analysis of the relevant issues nerc m, however, certain 

areas where we think that the discussion in rhe DPEIS needs to be expanded or danfied or where 

additionalissues need to be conaidercd. We offer the following comments and recommendat~ons to 

assist the Senrice in lmprovlng the spandmg rcsponse program and the DPEIS. 

CoUection and Spthesis of Da ta h Unusual Modty Events 

As mdcated m the DPEIS, Tide IV of the Mahe Mammal Froterhn Act requites, among 

other hings, that the MMHSRP "facilitate the collection and dissemination of reference data on the 

health of madne mammals and health trends of marine mammal populadons in the wild" and 

"correlate the health of marine mammals and marine mammal populations, m thc wild, with 

avaiLzble data on physical, chemicd md biological env~onmental parameters " The National 

Template Marine Mammal Stranding Agreement (p. 4) stares that one of the Service's 

rcsponsibilides, pursuant to section 402 of the M&nc Mammal Protection Act, is to "collect nnd 

update pe,iodirsUy and make av&ble to stranding network plmcipmts and other qualihd 

rwentish, wsmg mfomzdon on.. .stranding by region to monitor specks, numbers, conditions, 

znd closes of illness and death in strandcd madne mammals." lbe Commission notes, however, that 

of the 26 unusual monaliiy events that werc officially declared by the Working Group on Mhne 

Mammal Unusual Mortality Events betmeen 1991 and the end of 2005,' hal reports have been 

complered for only six events. Draft repoas have been prepared on three other unusual mortality 

events and papcrs have been pubhshed on seven addidonal events. This means that the 

armstances ad consequences of 10 events have not bccn reported. Such repoits are of potend 

value to stranding nebvorli pard4pmts and to researchers who arc responding to and seehg to 

undersrand such even*. The Commission behwes that a is lmpoaant that these repore be 

completed in a timely fashon. The Marine Md ComnU.mnu.sion therefore recommends that the 

Setvice (1) an update on the sht~~s of hd repow of unusual mottality cvenffi and (2) 

explore ways to complete and circulate hnal repom more prompdy. In hs regard, the Commission 

points m and endorses the rerommdations made m Gulland (2006) (enclosed; see pages 23 and 

24), whch identified several actions that the Sc~tc could rake to improve the utility of datn 

collected dung unusual modq events. 

Those recommended actions are consistent with the Setvice's mandate under Tide IV and 

would dancc the Service's Mame Mammal Unwd Mormliy Event Response Program. The 

I see ~ullnnd 2006. DI. Cmlland norcd that thm have bem 29 unurud momlity wcntr *nee 1992 We mcluded only 26 

mom mscussion bsmau$c the orher evenrr me curra~tly ongoing or wen closed ody rrecently. 

05/30/2007 6:47PM 

05/30/200i 18:41 FAX 301 504 0099 MARINE MAMMAL COMM. Boo4 

Mr. David Cottingham 

30 May 2007 

Page 3 

Marine Mammd Co~s~ion therefore recommends that the Smite revise the DPEIS to discuss 

actions the Setrice has taken or plms ro rake to improve the synthesis and use of data collctted 

during unusual mortahy events. 

Interim Standards far Release 

Tbe Intek Standards for Release appended to the DPEIS mclude several safeguards lor 

ensuring that marhe mammals are not released prematurely or in situations where they might pose a 

threat to wld populations. For example, the int& stzndatds requite that stranding network 

parriupants prepare "release determinadon recommcndnuons" and release plans and to obtain thc 

Setrice's concurrence prior to =elease. These rcquLements recognize that facilides my have 

mcenttves to promote inadvisable rclcases. The interim standards do not, howcuer, rccopc that 

for some specks, there may be a countervailing lncenhve to retain kc mammals for long-term 

maintenance in captivity and, perhaps, eventual placement st I public duphy facility. For such 

citcumstances, protocols necd to be cotabblished to ensure that the rehabImdon of animals ad that 

ptcparation for eventual release to the mld are pursued diligendy and mith suitnble agency oversight. 

The Commission notes that incentives to rctain stranded mimals for long-term capive 

maintenance likely ye geltest for species with commercdvdue, such as bottlenose dolphs, or 

for depleted speues for which public display pcn& are not available With only a few exceptions, 

rhese are species listed under the Endangcrcd Spctiw Act aa threatened or endangered. Thus, this 

may be an issue best addressed m the context of the new MMPA/ESA pennir being contemplated 

in the DFEIS. 

Page 2-2 of the Int& Standards for Release states that "[r]he Regional Administrator (it., 

NMFS staff) will rWim the rccommcndadon and rrlcase plan [submitted by a stranding faulrty] nnd 

provide a signed watten nohhcauon to the Strandmg Network partiupanr indicaung concurrence 

and authorization to release or kect an alternate disposition.. . ." The DPEIS does not, hut should, 

discuss the criteria that the Serviced use to review and approve or disapprove the 

recommendnnons pnd plans. The Comrmss~on's concern IS underscored by the Setvice's Southensr 

Regonal Office's authorization in August 2003 of the release of five pilot whales, despite objections 

from experts in the hlds of ceclcean biology, behavior, and vetednq medicine and contrvy to the 

Semite's ow release guidelines. fie animals in question induded a dependent calf and a juvede 

animal exhihikg aberrant behavior, prompting the ourside expcas to condude that rdearc ofthcsc 

minds would be inhumane. Under the Service's om grudehes, the release of dependent cahs and 

animals exhibidng aberrant behavior is precluded. Nine days after the hes' rcleasc, scientisu 

tracking the whales observed shuks amdring the calf, and thc fate of two 0th- a-$5 mas 

unknoum. In that case, the Service chosc not to follow its draft release aiteda and the advice of the 

majority of expcm it consultc%th advcrsc consequences. The Madne Mammal Cm 

thcrcforr rccommendr that the Smcc dmfq the procedures and substanfive cutena, other thn 

those &at facilities mould need to consider under the Intedm Standards for Release, rhar it WIII 

follow in reviewing and app~aving or disnpprox&g a stranding nelwork parddpant's 

recommendadon and release plans. 

05/30/2007 6:47PM 
05/30/2007 18:44 FAX 301 504 0099 MARINE MAMMAL COMP. m005 

Mr. David Cotdngham 

30 May 2007 

Page 4 

The Interim Standards for Rdcasc @ages 3-12 and 414) note that "[plost-rekase monitoring 

provides essend infomadon to dwelop and rehne mathe mammal rehabilitauon and rdesc 

pracaces." On page 2-14 it states that standardizauon of data collecuon protocols for mooitor& 

released animals may be helpful in comparing indwidual cases, and that the Scn?ce 'W provllk the 

stranding network with the desired format for receipt of tracking darn in repom? However, the 

Senlce does no= elaborate on what that format might be. We concur that vtlndardrzed data 

collechon protocols would be useful, and he Marine hlammal Commission recommends that he 

DPEIS be revir;cd to identify the types of lnformauon that would be induded in protocols for 

monitoring released anhala. 

Interim Standards forRe6abili~ation Facilities 

The lntroduchon to this sechon @age iv) notes that the In& Standards for Rehabfitadon 

Facilities establish minimum standards for the temporary care of animals undergoing rehbdihtion 

and that it is the Scrvicc'r intcnt to provlde n reasonable process for fadlitics to be upgraded to meet 

or cxcccd those standatds. Hoverer, there is no h&cauon of what thc Se~ce intends to do tc, 

ensute that rchabditauon fscilities are, in fact, meedng the minimum standards (e~g , whether 

mspections wll be conducted, how often, and by whom). The Marine Mammal Commission 

recommends that rhis infodon be provitlcd. 

Pages 1-4 and 2-4 state that shade structures or shelters must be provided when locd 

dunldc conditions could orhewise comprombc the hcdth of the mal. W standard is subjecfme 

aad allows Eor broad interprctiltion. The Service should better dehe the conditions under whch 

shade must be ~rovided to animals that are undergoing rehabilitation, recognizing that, if such 

vlunda ate vnable to themoteplate or svnm and dive normaly, protection from the sun is 

essential. 

Public Viewing ofMarine Mammal6 Undergokg Rehabilitation 

Page 6-3 of the DPEIS states that "[clurrently, public v~eming of aaimls ia rchabiliahn is 

not allowed under MMPA regulations.. .." ?he discussion gocs on to indicate that the MMHSRP 

"would Ik to estabhsh gudehes to allow public mewing that would protect the animals as weJl as 

the general public.. .." 

Con- to the statement in the DPEIS, rhe cited regulation (50 C F~R 216 27(c)(5)) docs 

not establish a complete prohhition on the ~blic display of mine mammals undergoing 

rehabilitation. Rather, such &plays are not dowed unless the Regional Director or the Director of 

rhe Office of Pmtccted Resources has specifically autho&ed them and unless they are conducted in 

a manner cons~stent vnth the requrements apphcable to pubk display. This being the case, 

reguhtory changes are not needed. 

The Commission concuts that cseblirhing guidelines for when and under what condrtlons 

public display should be allowed is a good idca. Howcvcr, the DPEIS does not sufficiently describe 

the types of guidelines being contemplated by thc Scrvlcc, cxcept to note that those Melines 

05/30/2007 6:47PM 

05/30/2007 18:45 FAX 301 504 0099 MARINE MAMMAL COMP. I2006 

MI David Cofingham 

30 May 2007 

Pagc 5 

would be designed to protect the animals md the general public, including animal and human health. 

It would be helpfdifthc 6md EIS e~panded on the Service's pbns for developing the guiddincr 

and identified other factors that need to be considered before public display of xnimals in 

rehabilirnrion fac&ues 1s suthonzed. For example, public display should only bc bcd in slmatioas 

and in ways in which it mould not interfere with the MMHSWs goal of evendY returning 

tehabittated mhe mammals to the wild (c.g., precauhons should be taken to ensure that viewing 

oppottunitles do not acclimate animals to the presence of humans). The Mnnne M-al 

that that DPEIS be rcvLed to elaborate on the Service's plans 

for developing draft guidelines to goo- whcn pblic &splay of mWne mda undmgomg 

rehabilitation will bc autho~ed, mduhg oppoaunides for the Commission, the affected facilities, 

and d~e public to rmcw the draft pidelmes prior to their adoption. 

p~ssible complicadng issue is whether pkung marine mammals undergoing rchabhtauon 

on public &splay cdggcrs Animd Welfare Act care and dtenance amdardr hat qht not 

otheiwise be applicable. Compliance with these standards mighr place additional hnaal burdens 

on rehabilitation facilities and codd deflect attention away from achi- the rehabfitation goals of 

the Mmne Munmal Pmtectlon Act. The Mame Mammal Commission thctefnre urpa the National 

Matine Fisheries Serice to work closely wirh the Animal md Plnnt Health Inspection Smce m 

developing rhe guidelines for public viewing to ensure that the requirements of he two starutes are 

mct and that the potcntid for successful rehabihtation is not compromised. 

Strandiog Nerwok Issues 

Over the yeas, three separate stranding-related issues have generated ongoing concern: 

insufficient spare at rehabilitation fadties, p&darly in light of the potend for increased 

numbers of standings in the future as a result of dimate-related changes; difficuldes associated ~irh 

placing non-releasable marine mammals (particularly pimipeds, neonates, and animals with chtonic 

hdth probkms [e.g., ncuxological problems nnd sldn condidons]) m pubhc display bdties; nnd 

ultena for deterrmrung when stranded mame mammals should be removed horn the vnld for 

meanent and rchabilitxtion fie., making on-scene evaluxtions of thc likelihood of I ~anded marine 

mammal bing succcsuMy rehabilitated and relcued). Clem and specific standards also are needed 

for deterhg when euthanasia of a sttanded aaimalis appropriate. We unders~nd that this and 

related issues are discussed in depth by Moore et al. (in press) and suggest rhat the Skcc contact 

the authors for a copy of that paper if it docs not already havc onc. The Commission belimes that 

an m-depth cxlrmnation of thcsc problcms and of potential solutions is watzanted. The Mnnnr 

Mammal Comrmss~on recommends that the Nahonal Mhe Fisheries Smce revlse the DPEIS to 

discuss these issues and possible strategies for addressing than 

05/30/2007 6:47PM 
THIS PAGE INTENTIONALLY LEFT BLANK 
May 1,2007 

May 30 07 04:30p Brenda L. Green P. 1 19071 443-5?60 .__.. ~- CVllllllClilb 

Suhject: comments 

Prorn: Charlcs Juhnsun -:CJ.AKNanuuq;~alashaLLcu~n~ 

Dntc: Wed, 30 May 2007 16:06:33 -0800 

To: m~nhsrpeis@noaa.gov 

"%,fJ <: ".;;A+~,.;": 2,- "* 2 

:,avid, 

'1:le ice Seal C'cnr1~t.t.r aL IL~ d~_ii-~L .!eeLiiiq u: Oc-, 116 ~dsied 3 :e;o:~L. sn ~gdir.~: tic relnt:roi;ilction of I?-zh sral '-to th? wi Ic, tee1 :he p3:intlal rlska of 1ntrocr:crd 

Fai.hiceZs fzr outwc~gn thc bcrcfits 3: a fcr rc;?:rodl.ozd nn-m3l.i to pop~t'a: inn- "at 

ulc .+.Cnlthy. Attached are ihe fm..~~Lra d~ri LIlr rcsui~.luri. T1.c ?\l,lska L~nuuy Coniilissior? 

at ~ts Dec. Ci, an?ual me+t:.ng also passed a resoi2tion aq,l!~sL Lt.2 irri.LrodicLiur. or rehan sects. 

C~IGL~~O CV~US:II, ZXCLUL~V~ DIL~c.;: 

A!;sk; \rerlaoq Comlsslo7 

loll 5;3012007 4:24 P\-1 

05/30/2007 8:33PM 

Mr. David Cotlingham 

Chiel; Marine Mammal and Sea Turtle Division (F1TR2) 

Ofice of Protcctcd Resources 

National Marine Fisheries Service 

13 15 East-West Highway, Roo111 13635 

Silvcr Spring, kID 20910 

May 30 07 04:30p Brenda L. Green P. 2 [907l 443-5_0_60 

05/30/2007 8:33PM 

Charles D.N. Rrower 

Ch*B111an. Ice Seal Comnit~cc 

PO Box 946 

Nome. Alaska 99762 

Sirbjec~: Rehabililatiorr arld Rcleax or Arctic Ice Sctalb 

near Mr. C'ottingham, 

The Icc Seal Comnlitlee is opposed to the release of rehabilitated ice seals in thc .kctic 

hack to the wild due to the threat of spread ofdisease. Current regnlations and policy 

require the release of marine marnmalr that arc deemed healthy Lo relurn hack lo the wild. 

Wc wish to have this practicc stopped for icc scaIs. We ha= passed resolution, as have 

the Eskimo Walrus Commission and the Alaslta Nanuuq Commission to opposc the 

release praciices k,r ice seals. 

Wc arc willirlg to work with the National Marine Fisheries Service and othe~ partner 

organizations to find ways to address the laws regulations, and policies regarding this 

issue. We hope to havc and exemption for the release of Alaska .4rctic ice seals rhat 

rcquircs thc release stipulations. We do no1 intend lo alli.ct other spccics wilhin Uniled 

Slates jurisdiction. 

Sincerely. 

~'hair6an. Ice Seal Comrmttee 
List of Participants: 

Mrnrbers 

Ctrarles D.N. 

llolly Chythlooh 

.\ustin .AIiniasuk 

Jennifer Hooper 

Jolio Gaodwii~ 

Wf 

Rex Snyder 

Charlei Johnson 

Federal 9eency 

Pete1 Bovciig 

Mlchael Cameron 

Barbaia Malioiiey 

(;t~esi Prerenters 

Urer~dan Krlly 

Lori Quakenbush 

Bob Small 

Paul Stang 

Lee Keliar 

Carrie iinerl, 

Monica Ricdel 

Other (ii~ests 

John Reynolds 

Cheryl Rosa 

Tim Licbling 

4!1n Hoover-Mlller 

Pam Tuorni 

Vitch Sirnionoff 

Vera letcalf 

Cllris Perkins 

Ilonna Willoya 

Chandra Meek 

Minutes of the 

Ice Seal Committee 

Alaska Nanuuq Commission 

24-25 October 2006 

Meeting 

Captain Cook IIotel, Anchorage, Alaska 

Organization Contact 

Brower Nortii Slope tlo~ongh CBroweri@Ukpik.con~ 

Bristol Ray N;ltive Assosicnrion mchytlilook@bbna.co~n 

Ka\verak lnc.iBering Shaigllts sub.rcc(p7hairerak.ur~ 

Assac. nf Village Council Prcsidcnts jhnoper@avcp.org 

Maniilaq JGuodwinGotz.net 

Aiaska Nant~uq Commission liarpoon907~~yahno.com 

Alaska Nanilliq Commission cj.aknanuuq,@aiaska.com 

hational Marine ivlanimal Lab peter.buveng@noaa.gw 

National Marine Mammal Lab Michael.comeron@noaa.go~~ 

National Marine Fisheries Scrvicc Barbaa.mahoncy:gnoaa.gov 

University ul Alaska Southeast brendan.keily@uas.alaska.edu 

Alaska Depariment of Fish & Gamc lori~quakenblrsh@fishgame.statc ak.us 

Alaska Department of Fish & Ga!ilc bob alnali@lishgamc 5tate.ak.u~ 

Minerals Mana~enient Service palil.srang$jmms.gov 

Alaska ScaLifc Ccnicr Ice.kellar@alaskascalifc.org 

Alaska SeaLife Center 

Indigenous Peoples' Council Marine Mamls monicariedel@gci.nct 

Mari~~r Mammal Commission 

harth Slnpe Rorough 

Alaska ScaLife Center 

Alaska SeaLife Center 

Alaska SeaLife Center 

Ala,kaUative ilarbor Seal Commissio~~ 

Ila~ka Sea Otter and Sea Lion Commission 

1:niveraily or ?Isska Fairbanks, Student 

Call to Order: Chairman Charles Brower called the ~neetulg of the Ice Seal Committee (ISC) to 

order at S:43am. 

Roll Call: Rex Snyder recogni~ed present Charles Brower, Austin Almasuk. Jcnnifcr Hooper. 

John Goodwin, and h,lully Chythlook. Quorum Established. 

Approval of Agenda: Motion lo approve ogencin h~, .ien~~fi.r- Fiooper, 2"" Afol!i. C'hylhfook. pasred 

ur~ar~i~~~ou.~~. 

A~~rovaI of Minutes: Motion lo approve .ianucrr~i 2006 and Febrzcary 06 Meefiitgs rnin7lle.s hy 

.4 isiin ilhrnasuk. _Y'?I~J .John Goodwin, passacl ununimolisly. I 

Charlie Johnson suggested that in order for the 1SC to be consistent with other commissions it 

should change its bylaws to be representatives fiom tribal entities not tribal governments. 

John Goodwin nlcntioncd that hc docs not work for Maniilaq but went to the board and asked them 

to appoint him because he was a seal hunter. He did not want to send an interior person to he on 

thc ISC and they appointed him. 

Charlie Brower suggested that an amendment to the bylaws he put forth at the next meeting and he 

wodd discuss the issue with Innpiat Cammrinily orthe Arctic Slope. 

Keeional Reports: 

North Slope: Charles Brower- good hunting in all villages this su1nn1er. Mr. Bn~wer personally 

had an excellent hm-est. Lost much dried seal meat eon1 seagulls. Somc scals unhealthy and 

unedibie hut not a bad season. 

MmiiIa.~ John Goodwin- a good harvest season. Stated that his region is losing old hunters. 

Subsistcncc Coordinator for 41aniilaq region connects families in need with hunters. A w-am fill 

season. Tk'hile out t'agying ltg~chaq noticed more ringed seals this year. The ringid seals were 

fatter and I~ealthizr looking Loo. Ilarvrsled ug-uk wcre not as fdt this year. Usually it is tlic biggcr 

uyrults with rusty faces but some ofthe young oncs had it too. John wants to know more about the 

red ljces and whac causes it. 

Kawerak Iilc./Berinlr Straits: Austin Ahmasuk reported on coniprehensive survey that includcd 

queslions on seal hdrvcst. Survey is in cooperation with ADFG and North Pacific Rcscarch Boa-d 

funding and is 80% complete. Official report should be available soon. ice conditions were very 

good - though trend in weather has been generally warm. Have not heard much in terms or 

diseases or unhealthy seals. Salmon on increase with record runs will help spottcd scals mostly. 

11 2002 survey will compliment the 2005 survey. Harvest seems normal from informal 

discussinns. This fall is warm and seems a bit behind in fieeze-up; a little late. 

Association of Villarc Council Presidents: Jennifer Hooper reported on not hearing any village 

concerns. late Spring break-up with grey summer and fall. Freeze-up is late. AVCIP-TI JM 

submitted a joint request fi~r funding with other Indigerlous Peoples' Council on Marinc Mammals 

May 30 07 04:30p Brenda L. Green 19071 443-5060 p.3 

i 

05/30/2007 8:33PM 

May 30 07 04:30p Brenda L. Green (9071 443-5060 p. 4 

05/30/2007 8:33PM 
lor line iten1 funding. JenniSer was approached by a museum wanti% an uyuk specimen for 

dhplay. She was uneasy about asking a hunter to catch food to send out and fill with plasiic for 

display. Howeverj request was retracted due to expense of such a display. 

Bristol Bay Nativc Association: Molly Cliythlook has rcplaccd Ralph Andcrscn as thc ISC 

rcprcscntativc. Molly Chythfook dcscribcd her affiliation with harbor scal smvcys with Alaska 

~btive Harbor Seal C'ommisison and AI>FCi in 13 communities. Numhers of sea lions harvested 

declined as numbers ol'a~iimals declined. Bearded seals are less ntunerous and timid. Mukluk 

sfjal's oil is yellow and lllust not get \varnl because it spoils easil). Togiak and Twin Hills reported 

skinny seals. I.ot of sea ice this year making open water skifuse difficult. Ice departed in time for 

normal herring harvest date. Raining and unpredictable summer weather made hunting difficult 

such as Round Island uralrus hunt. February April is the peak szal harvest and the harvest stops 

aftcr the salmon come in bccausc thc scals taste too fishy thcn. I-Iunting starts again in Octobcr. 

Conditions of skins seems to be degrading - cutting through skin easier when flensing blubber. 

Ausiin Ahmasuk said he has heard of thinner skins too. As a ripper ht: knows il could be o 

difference in the timing of the harvest because skins are thinner at certain times of year. Skins may 

be thinner when seals are molting too. 

I 

Tndiaenous Peoples' Council on Marine Mammals 

Monica Riedel gave an update and provided a handout titled "Alaska Uative Co-Managemeni and 

Consolidation ofIPCoMM2 dated 18 0ctobt:r 2006. She said thal the document was: the result of 

meetings and discussion and was initiated by IPCohfM members. She urged support from the 

Marine Manmal Commission and ack~~owledged support hom others. She asked for a resolution 

of suppo~t and letters to Senators md the Presidenr. John Reynolds from the Marine Mannnal 

Commission said that she should discuss hcr rcqucst with Tim Ragcn. the ncw7 Fxccutivc Director, 

b t that the MMC: planned a fall 2007 Co-management workshop. which may help. i 

Monica said that 11'CoMM7s message has ,already been delivered to Congress but no conlmitmcnts 

have been received. They are still optir~listic because the 07 spending bill has nor been signed. She 

gavc a copy of IPCoMM's agenda for ncxt nlccting to Rex. 

I 

SLafTReports 

I 

Rex Snyder gave an update on activities; fimding requests. and ice seal =mpling eforts in North 

Slope villages. Kes Snyder handed out a copy of an Arctic Sounder Article about seal hunt~ng and 

emphasized the usc of hlaslta newspapers to get infor~~tion out to conlmunities. Ile also passed 

out an organizational chrt for thc ISC. Rcx also niadc a plca for a bcttcr proccss for gctling 

money om NWS for ISC operations. He has been turning in receipts for reimbursement bur 

oiien he has no money to work wilh. NMFS responded that ihey could assist wilh that. 

Charles Johnson, Execntive Director of the Alaska Nannuq Commission (.ANT) pre7enled a report 

on activities of ANC. 'l'he primary focus has ken the treaty- with Kussia and thc Administrations 

hesitation to support congressional enactment due to language mandatiug the assignment ofjoint 

commission members as "Alaska Native": that the President may assign anyone he or she pleases. 

Highlighted orher pryjects ANC is involved with: Chukotka l'raditional Knowledge Study, 

Annotated Bibliography of Russian research, Treaty enaclmmt. FWS research on population and 

polar bear villagc patrols. 

RRE.4K 

tinfinished Business: 

National Marinc Mammal Lab (NMML)- Pctcr Bovcng and Mikc Camcron with Polar Ecosystems 

reported on seal capture and satellite tracking project from the Thotiias Tl?ompson research cruise 

vcssei at the lcading cdge ofpack- ice in the Kering Sea during April. .lohn Goodwin and C:harles 

Saccheus also psuticipated and felt that !laving Alaska Natives as research team members was vital 

and made For a very successfUl and advantageous for the program. KMML also gave an update on 

the Kopebue satellite tagging project. 

LUNCH 

Unfinished Business Continued: 

Austin Ahmasuk ewe a presentation on draft results from a Kawerak Inc. ballistics pro,iect on the 

effectiveness of .17 cal. and .22 cal. for seal hunting. Project provides information for hunters and 

could he transformed into a llandbook or other usefill tool. 

Dr. Kclly gavc an update on ringed scal population Inovcnlcnts and gcnctics that arc uscfiil Tor 

understanding population structure. Warm weather is attecting seal habitat with reduced ice and 

snow cover as well as limited denning seasons for pups. So Fa 338 ringed seal DNA samples are 

being analyzed so far from known breeding sites. 

Lori Quakenbush gave and update on ice seal biomonitoring in villages - working with hunters 

and users to gel rull suite of tissue samples and information. Prograril has sampled 1 ,I 02 seals. 

Alaska ice seal contaminant loads appear ncarly 10 times lower than the avcragc of thrcc sites in 

Canada. She also introduced Mark Nelson. ADFG, and a newly funded effort to collect ice seal 

harvest irfurmarion. The kinding includes money lor worhshops and meetiiigs to deicrn~irlc the 

best way to collect the inrormalion. The harvest calendars will also be a focus. 

Paul Stang with the Minerals Management Senlice provided information on Outer Continental 

Shclf oil and gas lcasc programs. Mr. Stang informcd Comlnittcc on MMS's Fivc Ycar Lcasc 

Program for Benufort and Ch111:chi sea lease sales. Chairman Brower suggested more wildlife 

monitors on board seismic vessels. 

Ncw Business: 

May 30 07 04:30p Brenda L. Green 19071 443-5060 p.5 

,- 

-, 

05/30/2007 8:33PM 

May 30 07 04:31p Brenda L. Green (9071 443-5060 - P.6 

05/30/2007 8:33PM 
Resolution Against the Release of Rehabilitated 

Seals to the Wild 

Ice Seal Committee Resolution # 01 -2006 

WHEREAS a stated purpose of the Ice Scal Committee is to preserve 

and enhance the marine rcsourccs of ice seals (ringed, 

bcardcd, spotted. and ribbon), and 

WHEREAS 

Alaska Sealife Center (AS1.C). National Marine Fisheries. and Ice Seal Colnmittee discussed 

strengths and wcakncsses oTrehdbilitdtior1 and release of actic scirls. Charlic Brower rcfcrred tc, 

the Resolutions passed by several ANOs, includiiig ISC, but releases are still continuing. ISC 

members reiterated concerns about introduction of parasites and diseases to the wild population 

and that the benefit of release of a few seals does not on! weigh lhe huge potential risk. 

1,ee Keller of the ASIC explained that their stranding agreement with KMFS requires the SLC to 

release rehabilitated seals meeting the release criteria The cunrni stranding agreement and 

policies between KMFS and ASLC require release of seals that mcct requircmcnts. ASLC gave a 

review oftheir rehabilitation program and what types ofthings they can lcam from livc but sick 

,animals. ASLC doesn't know how to honor the stranding agreement with NMFS and ISC 

rrsolulions. 'The short-term solution appears to bc for TSC to continue to promote local actions as 

laid out by the posters and pursuc a long-term solution such as an exemption in the MMPA for 

mzist he clear and slrong,for exemption. Passed unanimously. 

October 25.9:lOan 

Co-management Agreement discussion on any additions or missing elements. Rex Snyder 

reconnnended the agreement address sorrle enforcement issues. especially the concerns with bordcr 

crossings wearing traditional marine mammal clothing. Barbara Mahoney suggested the 1SC 

approach the Custom Agents for their newt meeting. NOAA Enforcement would also be able to 

attend the next ISC meting to answcr qucstiol~s on icc scal cnforccmcnt issues. No changes to 

.blotion hy Ausrin Ahmnsuk ro si,~i? Agreement. znd by Jennifir Ilooper. passed urzaiziii~o~i.~(~' 

Signed by Charles Browzr and Barbara Mahoney. Menlbrrs of Co-managcnie~~t Conullittcc 

WHEREAS 

appointed are: All 5 rnembcrs of Ice Seal Committcc and Pctcr Bovcng, Barbara Mahoney, and 

Kaja Brix. 

Back to Unfinished Business: 

Technical Committee: Peter Boveng took lead on discussion to review and update Ice Seal 

Reseach Plan as a guide and tool for fiscal proposals to Congrcss and rcvicwing icc scal work. 

Discussion on introduction to reflect emphasis on promoting needs for funding - with a clcnrcr 

voice for broad audience. Charles Johnson will be in D.C. in mid November and would like 

updated introduction of the research plan for 11s trip. 

.&fotion by Avslin Ahrnasuk lo tnbk eleclionsjor next meeting, 2"Qhv .John (;oodwin, pnsseil' 

~rnunirnozi.~~~. 

Adiournn~ent: Next mcctu~g at thc call of the Chair Motion to adjourn by Alr~tin Ahmtcst,k, Td 

hy .John Goodwin. passed unonimol~sly. 

:,J05/30/2007 8:33PM 

WIIEREAS 

05/30/2007 8:33PM 

healthy icc scal populations are important for the 

subsistence of coastal Alaska Native pcoplc of the 

Bering, Chukchi, and Beaufort Seas, and 

the practice of transporting a sick ice seal from its Arctic 

environment (Bering, Chukchi, or Beaufort Sea), nursing 

it back to health in waters from thc Gulf of Alaska, and 

releasing it back into the Arctic creates great potential 

risk of introducing diseases andlor parasites into the wild 

ice seal populations, and 

there is no population crisis for any of the ice seal species 

that would justifj the potential risk of releasing a few 

individuals back to thc wild, then 

BE IT RESOLVED that the Ice Seal Cornmittec is opposed to this practice 

and will act locally to prevent sick ice seals from being 

transported for the purposes of rehabilitation and release. 

3 1 January 2006 

Date Charles D. N. Brower 
S Sarasota Dolphin Research Program 

AcolwedhEllorrdlh. 

W-l-mdMoh*- 

C'OYoby.~~ 

16m~m~kanpon- ~hmr: (nib =nos 

&msd~,FbrWSu31UJA Fax: (P11)- 

--.m 

00

r

anding response organizations is welcome and all of your work is

ns regarding the “Policies and Best Practices: Marine Mammal

standards for Rehabilitation Facilities” specifically as it pertains to

ents.

s for them to meet USDA, APHIS regulations. These standards are

d in that pool and were developed for permanent display facilities. 

itation facilities like ours who handle primarily pups and juveniles of

ely, if ever, strand in our area of response as adults. Also, it is not

pools used for rehabilitation or only those used for holding animals in

 for your time and consideration.

5/30/2007 9:00 AM

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 • Buzzards Bay, Massachusetts • 02532-0269 

9-5477 • nmlc@nmlc.org • http://www.nmlc.org 

30 May 2007 

Division 

 Fisheries Service 

the Marine Mammal Health and Stranding Response Program 

tement. The document is thorough and thoughtful, and 

on the part of MMHSRP program staff to support and 

tives. 

 Agreement criteria, use a new SA template, and include 

nized carcasses offsite when possible and practical. 

ments, continue rehabilitation activities, and implement 

ements, continue release activities, and implement Release 

of the Disentanglement Network on the east coast, to 

nt Network on the west coast, and to implement 

uisites. 

permit to include current and future biomonitoring and 

maintaining Rehabilitation Facility Standards and all other 

eferred alternatives, I urge NOAA to continue and expand the 

ram. The Prescott Grant Program has been responsible for 

ng response, rehabilitation, and release. Additionally, the 

ficant advances in science that continue to improve our 

at relates to oceans and human health. 

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Aquarium May 30, 2007 1

on 

d Aquarium, a stranding agreement holder in the 

he Draft Programmatic Environmental Impact 

 and Stranding Response Program. We support NOAA 

e national marine mammal stranding and 

 the effort that has gone into these documents and are 

mments. 

tranding Agreement and Response Alternatives. We 

cause the risk to public safety is too great. If trained 

ured or distressed marine mammals the public will take 

een in the past. We also reject Alternative A3 and A2 

on and guidelines for the national network. We 

A in their goal to offer guidelines, minimum criteria and 

nt of a Policies and Best Practices Manual, we are 

roughout that add new or increased responsibilities 

 supportive of the cooperative relationship that we have 

nstant addition of new requirements in reporting, 

ain to organizations that have minimal staff, funding, 

stline and a large number of stranding responses each 

nal Stranding Agreement Template

guage in the NOAA deliverables section is quite 

n the Stranding Agreement Participant section. The 

des the phrase “as needed and as available,” while in the 

e wording changes dramatically to the participant “shall 

propriate to clarify the financial liability, we believe 

ne exists, of all Level B or C data they request. 

New England Aquarium May 30, 2007 2

Alternatively, the language could be changed to closely match the NOAA section; for example: “as needed and as funds are available”. 

2. Article II section B lists the NMFS responsibilities. It would be helpful to the Stranding 

Agreement Participants to understand the experience level and qualifications of the NOAA employees in its region. Stranding Participants are all required to provide such information and it seems prudent the NOAA agree to do the same. 

3. Article II, section C, part 4 states that the stranding participant shall bear any and all 

expenses incurred with the taking, collection, or other activities pursuant to this agreement. NMFS may be able to support costs associated with specific analysis and additional requests as funds are available and authorized. This section should clarify that these activities do not include the towing of large whales. We also suggest that the language reflect the fact that activities will be based on the financial resources of the Stranding Participant. If the Stranding Participant does not have the resources available then the samples cannot be collected, shipped, or analyzed. Language used in the NMFS responsibility section such as “as resources are available” would be appropriate here. 

4. Article V, section B1, part f states that the stranding participants “shall prohibit the public 

display and training for the performance of stranded rehabilitating marine mammals as required by 50 CFR 216.27 (c) (5). This includes any aspect of a program involving interaction with the public.” We feel that the sentence, “This includes any aspect of a program involving interaction with the public” should be clarified and the terms defined. As it stands this would eliminate many highly effective yet non-detrimental education programs currently in progress. It would significantly impact many facilities that have free visitation programs to their rehabilitation centers. 

Specific Comments on the Evaluation Criteria for a Marine Mammal Stranding Agreement (New Applicants and Renewals)1. Section 2.1 General Evaluation Criteria for Articles III, IV, and V Authorization 

section 10. This section states that a prospective SA must apprentice under a SA holder for a minimum of three years. We suggest that NOAA assign a number of rehabilitation cases to meet the minimum requirements rather then length of time. 

2. Section 3.2 states that key personnel are required to have necropsy experience, but 

this seems unnecessary if level B and C data is only collected “if possible” as is stated in this section. If necropsies are not required, why is necropsy experience for staff? 

3. Section 4.2 Qualifications for Article IV Authorization section f. Although it 

states that this qualification is “preferred but not required” it should be removed 
Aquarium May 30, 2007 3

ed to only a few geographical locations throughout 

Article V Authorization section 1 c. “Experience in 

efined. Does this mean supervising volunteers and 

or supervising the rehabilitation case? 

Cetacean Rehabilitation Facilities

 and Space

neonate cetaceans, if the rehabilitation facility is 

ey should also provide an updated staffing plan to 

cean would likely require 24-hour care for weeks 

reparation. Bullet three states, “Diets reviewed by 

veterinarian.” This request seems excessive. Most 

nist on staff, even the large facilities like the New 

be enough that the attending veterinarian and the 

e the diets. Requiring that a nutritionist review all 

bitively costly for the majority of the rehabilitation 

d veterinary staff can manage this. 

Minimum Standard bullet three states that a girth 

 weekly on cetacean rehabilitation candidates.

beginning stages of rehabilitation, weekly captures 

very other week would be more appropriate with 

rehabilitation.

ience states that veterinarians be available to assess 

events. This should be clarified. In many smaller 

ot on site but consulting via phone. We 

ons Participants often act on their own accord with 

erinary oversight. Wording needs to provide direct 

hould also not cripple more responsible mass 

k consistently under the direction of veterinarians. 

hat section is states the vet be a full time employee 

cord at facilities managing ten or more cetacean 

arify if that included live and dead animals or just 

irement could prove prohibitive for smaller 

 cetacean numbers. Section 2.7.1 in the Pinniped 

he vet consult with the vet on record at facilities 

es per year. Does this included dead animals? If 

MFS new direction of making difficult decisions. 

New England Aquarium May 30, 2007 4

5. Section 1.7.2 Veterinary Program section, Minimum Standards. This section 

taxes the veterinarians with a lot of paperwork that seems excessive, particularly bullet two, which requires a review of Standard Operating Procedures every six months. One time per year is sufficient. Smaller facilities or those not associated with a larger park or Zoo have contracted veterinarians who have another full time job in private practice. While we strongly support veterinary oversight we also think the demands on the veterinarian’s time should be reasonable and focused on animal health and direct animal care. Non-veterinarians can perform some of the tasks listed here. 

6. Section 1.9.1 Record Keeping: Bullet 13 states that medical records should be 

available for NMFS review upon request. It should be clarified that this statement does not mean that NMFS is able to retain copies of the medical files or diagnostic results, because these are level B and C data and are owned by the Participant. This should be modeled after the AFIS regulations where regular inspections and reviews take place but AFIS does not retain copies. An agent visits the facility and reviews the documents in house. Bullet 14 states that medical records must be kept on site for a minimum of 15 years. It should be clarified if this means hard copies or computer copies. Computer copies can be kept more easily, whereas hard copy storage may be problematic. If this refers to hard copies then ten years on site or fifteen years at a secured storage area should be sufficient. (This is restated in the Pinniped section). 

7. Section 1.14 Training and Deconditioning Behaviors states the staff veterinarian 

should evaluate the benefits of training. We recommend that a person with at least three years of operant conditioning with cetaceans be consulted regarding the training plan and the plan for deconditioning. Phone consult would be sufficient before, during and prior to the deconditioning. Many marine mammal trainers will provide support free of charge. 

Specific Comments on Release Criteria 8. Section 3.8 Marking for Individual Identification of Cetaceans prior to Release. 

This section suggests three forms of identification prior to release. One of these is non-invasive while the other two are invasive. We are concerned about freeze branding and whether this is really necessary with a dorsal or satellite tag in place?
adfoundation.org>

unity to comment on the draft EISnterim policies and best practices,litation and Release.his document are acceptable as longome regulations. The major issues Iinimum and recommended standards. Iw they would be weighted if theyes will aspire to meet the minimumHowever, if the recommended require an additional upgradeducting rehabilitation. Theseurce of funding not able to bett Rescue Assistance Grant Program.upgrades is through this grante diverted from general operational meet our obligations operationally.we currently do not have enoughproposals) when the burden oft.eneral operations will increased are as follows. By increasing theion tanks to a weekly cycle labidual pools for each animal would. When looking at staffinges, if we were to maintain 24-hourble at the current rate. The to be absorbed if Prescott Grantmarine mammal stranding facilitiesmbers and species composition of facility and many others to maketaffing levels in addition to our facility does not currentlyoccurring in our region there would facility to comply with the newdelines set forth to deal with strandings and rare occurrencesment is that all references to tank on actual animal size beingverage adult length. These changesacilities during construction andother problem associated with theseerations of the rescue program. Ifncide with a decrease in the number to be secured. It would be helpfullan, based on their need assessmentities so as not to create aeeaned cetacean calf forsubmit a plan to the NMFS regionalnd timeline for decisions regarding that means receiving from another, as most assessment would be done

6/1/2007 6:59 AM

upon arrival at the facility. It should be modified to “shortly afterreceiving an unweaned cetacean calf for rehabilitation, facility personnelmust submit a plan to the NMFS regional coordinator which will includeoptions and timeline for decisions regarding disposition”Section 1.1.1 Space requirements for pool, bay, or ocean pensThe statement “pools shall have a minimum horizontal dimension of 9.75meters (32 feet) or two times the average adult length of the largestspecies in the pool, whichever is greater” should be changed to “pools shallhave a minimum horizontal dimension of 9.14 meters (30 feet) or two timesthe actual length of the largest species in the pool, whichever is greater”Section 1.1.4 Critical Care Animals and CalvesThe statement “control air temperature above the pool between 50 – 80°F whenappropriate to facilitate recovery” should refer to the environmentalparameters encountered by the species undergoing rehabilitation.Section 1.3.2. Frequency of testing in closed, semi-open or open systemsThe statement “maintain records for tests with time, level and results –reviewed and signed monthly by the attending veterinarian” should add “or ahusbandry care specialist”Section 1.6.1 Diets and Food PreparationThe statement “diets reviewed by a nutritionist and the attendingveterinarian” should be altered to “diets reviewed by a nutritionist,attending veterinarian or animal care specialist”Section 2.1.1 Pool requirementsThe statement “facilities where numerous pinnipeds are rehabilitatedconsistently each year should be equipped with at last one pool and haul-outarea that meets APHIS standards for at least one adult of that species whereone or more per year strands as adults” should be altered to “facilitieswhere numerous pinnipeds are rehabilitated consistently each year should beequipped with at last one pool and haul-out area that meets APHIS standardsfor at least one adult of the species when the average of occurrenceincreases to one or more per year.Thank you for you consideration in this matter.Robert A. DiGiovanni Jr.Director / Senior BiologistRiverhead Foundation for MarineResearch and Preservation467 East Main StreetRiverhead NY 11901Office: (631)369-9840Fax: (631)369-9826Hotline:(631)369-9829

2 of 2 6/1/2007 6:59 AMATTN: MMHSRP PEIS
1

Y NATIVE ASSOCIATION

PO Box 310

am, Alaska 99576-0310

l: (907) 842-5257

x: (907) 842-5932 

May 31, 2007 

nservation Division 

ce 

ssion, and the Bristol Bay Marine Mammal Council, 

ent on the Draft Programmatic Environmental Impact 

and Release of Marine Mammals.’ I also work for the 

Mammal Program which serves thirty (30) federally 

giak to the Nushagak Bay and Nushagak River 

sub-region, the Naknek area, and the Alaska Peninsula 

coastal and inland communities totally rely heavily on 

od resources which include marine mammals (bearded 

als, beluga whales, Steller sea lions, Northern sea 

 are an integral part of the culture and economy in 

ime immemorial. Traditionally, Native hunters have 

or sustenance and still do not today. Native 

rine ecosystem can provide including seabirds, 

her shellfish species found in the marine environment. 

a year-round cycle in harvesting the marine mammals, 

 smelts, hooligans, Northern pike, whitefish, Dolly 

od fish, herring eggs, clams and other shellfish. 

or furbearing animals, and gathering edible berries, 

Native way of life. There are oral traditional Native 

 gatherers adhere to continue to be provided by 

ve people were taught by their ancestors to treat the 

respect; to get only what they needed and leaving 

2

enough eggs, fish, and animals behind so more will be available next season. This is still a part of conserving the natural resources by the Alaska Native people. The Alaska Native people were taught not to leave the place where they harvested traditional foods disturbed and messy. They were taught to properly dispose of unedible animal parts either to designated land and sea areas. Today, hunt captains have a process they go by in screening their hunt crew to ensure a successful harvest by abiding by the Alaska Native traditions. One of the practices, the Alaska Native’s was taught was not to play or treat animals disrespectfully. This is one of the reasons, the majority of Alaska Native communities do not support some of the Western scientists, and institutions research projects. The animals are not to be touched or played with was one of the traditional Alaska Native customs, otherwise if the hunter hunted, slowly, the animals or game he hunted will eventually become scarce. These very important Alaska Native traditions or customs need to be respected by researchers. Cooperatively working with the respected communities of any proposed projects need to be presented to the village council’s for their approval. One of Bristol Bay Native Association’s goals is to build local capacity. One information and or way of doing this is to hire local people to provide expertise in a project because they are knowledgeable about their environment and their traditional hunting areas. A simple courtesy can go a long ways. The main concerns I would like to address include release of marine mammals after they have been rehabilitated; freeze branding or marking marine mammals for research purposes; and prescribing medicines to marine mammals. My other comment will be recommendations of this Program to conduct statewide/regional marine mammal stranding workshops in coastal Alaskan sub-regional hub communities in the Bristol Bay, and the Alaska Peninsula. Release of Marine Mammals After Rehabilitation

We do not support releasing marine mammals after they have been rehabilitated to a different area than from where they originally came from. One of the Bristol Bay Marine Mammals concern is if the Alaska SeaLife Center or agencies rehabilitating a marine mammal, and releases it to a different location than where it originally came from, various diseases, parasites, and new illnesses can be spread to the marine mammals and other marine resources. The recommended process for agencies that rehabilitate marine mammals from communities is to work with the local village council where the call originated from. The Alaska Native traditions is if a baby marine mammal is observed, do not touch it thinking it is orphaned, because usually the mother is nearby feeding and sometimes they feed up to a day. The majority of coastal communities recommend leaving the orphaned baby animal alone, and let nature take care of it. An educational flyer needs to be made about observing marine mammals that may be orphaned, stranded or ill and be sent to all Alaskan coastal communities. I have received some calls from Bristol Bay communities of marine mammals thinking they were orphaned, and they went ahead and called, for example, the Alaska SeaLife Center, or the local National Wildlife Refuge offices without contacting the local village or traditional councils. The recommended procedure is if a call is made to, for example, the Alaska SeaLife Cent to rehabilitate a baby animal, contact the village council. Find out who the Village Council President or Vice-President is and follow their recommendations. If they approve to have the animal rehabilitated, then the person can also contact their regional Native Association marine mammal program, the Refuge, and Fish & Game offices to cooperatively rehabilitate the animal upon approval of the Council. These types 
3

ammals

l and state agencies have conducted is 

and hides for research tracking purposes. This was a 

y between the Alaska Natives and the Federal 

ponsibility between the Federal Government and the 

al way of life to ensure it will continue on into the 

vesting marine mammals for food, to use the fur for 

overing the traditional qayaq or boat. These so called 

was done without the permission of the local coastal 

vest seals. There have been studies done by so 

e mammal population trends, genetic research and 

s long as the marine mammal is not ‘played’ with 

y. Some of the marine mammal studies have 

ne of the reason is Alaska Native traditional customs 

reeze branding or marking any animals in the sea, the 

us, a population of an animal can misteriously decline, 

can become scarce for an unknown reason. These are 

sider before Western scientists touch the animals eaten. 

e lower ’48 and relished by a majority of Americans, 

heir seal oil, dried seal meat, and traditional delicacies 

iled goods. Therefore, we do not support any freeze 

als in coastal Alaskan waters. It would be beneficial 

cal Alaska Native Organizations or Village Councils or 

hem with any proposed research projects including 

s. 

Marine Mammals

e Mammal Council, the Qayassiq Walrus Commission, 

s prescribing or injecting medication to marine 

want to ensure the marine mammals they harvest are 

ee. They understand and trust agencies which get 

that the animals will be analyzed and results will be 

 manner. Due to the high cost of fuel, and oil, the 

ger until they harvest marine mammals. For example, 

proximately $ 6,000 to traditionally harvest walrus at 

will try to get their quota of four walrus. The walrus 

ll be shared with the surrounding Nushagak Bay 

hy animal is essential for the survival of several 

ontinue to hunt and harvest healthy marine mammals 

4

Other Recommendations

I am enclosing the Bristol Bay Native Association’s Policy Guidelines for Research In Bristol Bay, Alaska adoped by the BBNA Board of Directors for your information. For further information on the communities served by the Bristol Bay Native Association, you may connect to the following BBNA web link site at: http://www.bbna.com/who.htm.

Thank you for considering our public programmatic EIS comments and we look forward in working with you in the future. Sincerely,Bristol Bay Native Association Helen M. Chythlook Marine Mammal Coordinator Enclosure: Bristol Bay Native Association Policy Guidelines for Research in Bristol Bay 
 NATIVE ASSOCIATION 

OR RESEARCH IN BRISTOL BAY 

e BBNA Board of Directors, are consistent with 

n of Natives in May of 1993 and shall serve as 

 Bristol Bay region. 

h the scientific community an interest in learning 

our societies. The best scientific and ethical 

Natives are directly involved in research 

tudies where the findings have a direct impact on 

ate institutions that conduct or support research 

hat they include a standard category of funding in 

ation. BBNA recommends all scientists and 

es among Alaska Natives in Bristol Bay to comply 

o be affected by the study of the purpose, goals 

the data-gathering techniques, and the positive 

 research. 

the appropriate governing body, village or tribal 

ort or the resolution process. 

assist in the study with the intent to building 

. 

veys and sensitive material. 

e participants by compensating them for their 

volvement. 

ns of affected communities. 

nities where English is the second language. 

mmunities with the opportunity to comment on 

draft is released. 

cknowledge the contributions of Native resources 

 

ges in a summary and in non-technical language 

y. 

 local library, villages, agencies and other 

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@hotmail.com>

ces Marine Mammal Stranding Response, Rehabilitation,

lities<?xml:namespace prefix = o ns =

tion Facilities

scretion of the attending veterinarian” be applied to many if

s arise during medical treatment and rehabilitation of stranded

mental to their recovery to follow the standards. For example,

ely limited for animals with fractures. 

habilitated species, their growth rates, and varying sizes at

space requirements should be based on the individual animal

measurements of adults of the same species. 

f 60-80F is too narrow and unrealistic. The range should be

 wild, with protection from extremes of heat and cold. 

, Sec 3.110(b) 

 and medical training need not meet the minimum space

f a marine mammal in a medical treatment or medical

ace requirements for periods longer than 2 weeks must be

nding veterinarian must provide justification in the animal’s

medical treatment and/or medical training is to last longer

writing by the attending veterinarian on a weekly basis.

7/10/2007 2:53 PM

Since the USDA-APHIS standards make a specific exception for medical treatment, and since rehabilitationfacilities are by definition providing medical treatment, there should be no requirement for rehabilitationfacilities to meet the same USDA-APHIS standards for marine mammal housing for long-term/displayfacilities. The exception for medical treatment should remain.To reduce paperwork, particularly in high-volume rehabilitation centers, we suggest that an exception be madeto the required weekly written justification for holding animals under medical treatment. Holding inappropriate facilities for medical care should be permitted until the rehabilitated animals are deemed healthy forrelease by the attending veterinarian. Veterinary discretion should apply to all pool dimensions, not just surface area of the pool, as written in therecommended standards.1.2 Dry Resting AreaThe description of how to calculate dry resting area is confusing to read. We suggest that a table be prepared,based on body length, for the required surface area. This table could be similar to the one for cetaceans in9CFR3.104, which is based on body length and not on species. 1.6 Air TemperaturePlease clarify whether the proposed minimum standard applies to indoor facilities only. For outdoorrehabilitation facilities, there is no practical way to control ambient air temperature. Suggest that if protection from extremes of heat and cold are provided, such as access to heating pads, shelters,shade, water spray, etc., the holding of animals in such areas should be at the discretion of the attendingveterinarian. 1.7 Housing for Critical Care AnimalsThe language in section 1.7 is more generally appropriate for ambient conditions: provide shelter fromextremes of heat or cold, and provide heat as appropriate for animals held in cold climates.Please clarify what “appropriate in size” means for individual dry haul out space or individual enclosures. Providing a structurally separate quarantine facility for all incoming animals in not necessarily appropriate orfeasible. If there is adequate separation between portions of a structure and between animals, that should

2 of 8 7/10/2007 2:53 PMComments on draft rehab standards
of the attending veterinarian and/or trained husbandry staff. 

ung animals helps to decrease stress. 

not appropriate, as animals in the wild often haul out and

ay be appropriate and necessary for critically ill animals, but

arian. 

 cleanable excludes most if not all natural items, such as kelp,

us and easily cleaned, that they be disposable and not shared

mal or group of animals. 

chemas-microsoft-com:office:smarttags" />Pest Control

 and all wild animals (i.e. birds, small rodents, insects) is not

ol is appropriate. 

tat range is not feasible, nor is it necessary for short-term

otect from extremes of heat and cold,” as in other sections. 

ansmission

ry or appropriate. Please insert language indicating that batch

s are often admitted in groups during seasons.

appropriate. Suggest changing this to the provision of

 wear shields or glasses at their discretion. 

mal transmission of disease

7/10/2007 2:53 P

M

It is not practical to build perimeter fencing that will prevent all wildlife from entering the premises. Suggestdeter instead of prevent. Similarly, it is not practical or even desirable to build net pens that will keep all wildlife (i.e. fish) from cominginto contact with rehab animals. 3.6 Methods to reduce spread of disease from animals housed in open sea/bay pen systemsPlacing a second set of perimeter nets 30 feet from the pens is not practical nor always desirable. We suggest that placing pens 1000 m from storm drains is not practical (i.e. run-off from building roofs, etc.,can be considered storm drains). Limit this requirement to sewage outfall. Daily coliform testing for net pens is not practical. Pens may be located in remote areas where testing cannotbe carried out, and it is also not feasible to control the coliform count in open water areas. 3.7 Evaluation requirements before placing marine mammals togetherObtaining full bloodwork, cultures, etc., is neither practical nor appropriate in all cases. For example, diseasessuch as leptospirosis, which is endemic in certain wild populations, can be presumed present in certain groupsof animals, and they can be housed together appropriately without extensive preliminary testing. Please clarify the meaning of contingeny plan. Is this a treatment plan for the various conditions listed? Housing plan? Please also clarify which diseases are reportable for marine mammals, and to which agency. CDC? WHO? OIE? USDA? Suggest that a table would be helpful. 3.8 Zoonotic considerationsThis section is very vague. All pinniped handling may result in exposure to potentially zoonotic pathogens. Sodoes all handling, including beach rescues, require full protective gear? 5.0 Food, Handling, and PreparationSuggest check of wild pinniped foraging literature, as there are many reports that pinnipeds will forage and thenhaul out for several days. 

4 of 8 7/10/2007 2:53 P

M

Comments on draft rehab standards
group, then kCals consumed can be calculated if/when

aily calculation is adding unnecessary work. 

y used be calculated. 

ds for each batch. It is not necessary for each facility to

iduals when they are housed in groups. Group records can be

tes and weekly records of weight provide sufficient indication

nd after feeding to individuals or groups. 

ertify that animals are likely to survive, or that they are free

est for all known communicable diseases, so we cannot

ple, E. coli is a potentially communicable pathogen, and all

re appropriate standard is that animals must be free from

nd free feed. 

 plan. Is a preventative health program required for all

gemistry is sufficient, as admit and release exams may be the

7/10/2007 2:53 P

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same in many cases. Additional testing should be at the discretion of the attending veterinarian. Measuring girth is not practical in all cases, for example when manual restraint of large animals is used forexams. Most formulas are based on length and weight, so standard length and weekly weights should besufficient. Suggest that girth measurements be recommended but not required. Suggest that complete necropsies performed within 72 hours are sufficient, and that 24 hours is not practical. Suggest that histopathology on select tissues is at the discretion of the attending veterinarian, as for cultures andother diagnostic sampling. Please clarify which disease are reportable for marine mammals (see notes above), and also which diseaserequire notification to NMFS. Release should be at the discretion of the attending veterinarian. Advance notice to NMFS is not alwayspractical nor in the best interest of the animal, e.g. animals very stressed by captivity. 

For recommended standards, frequency of blood sampling beyond the single collection should be at thediscretion of the attending veterinarian. Please explain the utility of banking the buffy coat. Suggest that it be performed on selected animals onlysubject to utility. 8.1 Record KeepingUnder recommended record keeping: Please define the set of standard morphometric measurements that should be collected and include a suggestedrecording format.Suggest that obtaining photographic documentation of all animals is not practical and of questionable utility. Animals with distinguishing markings, or other unusual features could be documented. 

6 of 8 7/10/2007 2:53 P

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Comments on draft rehab standards
 the daily caloric intake for each animal. This is not practical

lume centers. If caloric value of commonly used diets is

d on weight, that should be sufficient. Additional

nding veterinarian. 

 in too much handling. Suggest that weekly weight be

attending veterinarian. 

parative data.” 

7/10/2007 2:53 P

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Draft rehab standards response.doc

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8 of 8 7/10/2007 2:53 P

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Comments on draft rehab standards
06/14/2007 15:03 2022086970 PEP PAGE 02/05 

United Stares Department of the Interior -4 

OFFICE OF THE SECRETARY , -w 

Warh~ngron, DC 20240 TAKE PRIDE" 'NAMERICa 

JUN 1 3 2007 

In Reply Refer To: . , 

ER 071332 

I, ' 

Dr. David Cottingham 

Chief, Marine Mammal a~id Sea Tu~lle Conservation Division 

Aitn: MMIlSRP DPElS 

Office of Protected Resources National Marine Fisheries Service 

13 15 East-West Highway 

Silver Spnng, Maryland 20910 

Dear Dr. Cottingliam: , . 

The Department of the lntenor has revie\ved the Draft Programmatic Environmental Impact 

Statement (EIS) for the Marine Mammal Health and Stranding Response Program (MMHSRP). 

The noticc of availability for this Draft Programmabc EIS was published by the Environmental 

Protection Agency in the Federal Regisrer on March 16. 2007 (72 FR 1261 1). 

The Depdrnent has received comments from the Fish and Wildlife Service (FWS) in response 

to our revlcw request. With ths exception of section 408. thc MMHSRP is a program created 

and implemental. as authorized under the Marine Mammal Protection Act. by the Secretary of 

Commerce. Therefore, lor the most pan, this Draft Programmatic EIS rerers to management of 

ma~ine mammals under thelurisdiction of thc National Marine Fisheries Service. i.~., cctaccans 

and pinnipcds (except the walrus). Accordingly, the Department's commcnts are limited to those 

involving marine ~namrnals under the management jurisd~ction of the Secretary of the Interior: 

ie, manatees. sca otters. walruses, and polar bears and. those actions that overlap with the FWS 

management regimes. Our comments are provided in the enclosure. 

We appreciate the oppoflunity to provide thcsc comments and hope that they prove to be uscful. 

If ),on lha>e any questions regarding specific technical issues in these comments, please direct 

them to 1hc Fish and Wildlife Sewice's Martin Rodis. Chief. Bwlch of Rcsource Management 

Support. at (703) 358-2161. Fo~.all other questions, you may coutact Ken Havran in the Office 

oTEns~ronmental Pol~cy and Compl~a~ice at (202) 20 -71 16. d.$!, Willie 

44' 

R. Taylo~ ' 

Director 

Oftice of Eiivironmental Poltcy 

and Compliance 

tnzlosure 

06/14/2007 2:36PM 

06/14/2007 15:03 2022086970 PEP PUGE 03/05 

Enclosure 

Department nfthe Interior's Comments on the Draft Programmatic EIS for the Marine 

Mammal Health and Stranding Response Program 

Qa~ter 1 I'urpose and Need for the Pronosed Action. To be all inclusive. the Department 

recommends tlle following additions to the second 11111 paragraph on page 1-1 0 concerning 

undcr the Convention on Inte~national Trade in Endangered Species or W~ld Fauna and 

Flora: 

"For irnport andexpon of marinc mammal specimens. the MMHSRP may bc required to have 

import and cxport permits, if the species is lrsted on the Convcntion on International Trade in 

Endangered Species of Wild Fauna and Flora (CITES) Appendix I. 11, or 111. The CITES peqits 

For import and export are issued by the FWS and are required to import and export samples, 

parts, carcasses. or live animal specics (for treatment or release) listed in the CITES Appendices. 

Species listcd on CITES Appendix I require both an import permit and an expo* permit be 

iswed for international shipments. Species listcd on CITES Appendix 11 only require'an export 

pe~mit. unless the imporling country has strictcr measures than CITES. The only marine 

mammal listed under Appendix 111 is the walrus. 0bobenii.r rosmarus; either an export pennit or 

a certificate of origin is required for each mternattonal shipment of walrus specimens." 

- C1,a~t.z~ 3. AffecLed Environment. 

On page 3-24. the paragraph titled UMEs identifies sevcral unusual mortality events that have 

occurred over thc years. Wc notc that a UME was declared for soutbem sea otfers in 2003. 

Unless this even1 is being lumped with tlie "Multi-species UME for 2003, the 2003 southern sea 

otter UME should be mcluded in this paragraph. 

On page 3-28, firs1 line. including the polar bear. there arc twenty-nine marinc mammal species 

that have the potential to occur in the Alaska Region This change also needs to be made to 

TaYe E-I 8 in Appendix E (see below). 

Also on page 3-28. inserr the following sentence on line 4 before the sentence beginning with 

"Endangered species include . . . ": "On January 9,2007, the polar bear was proposed for listiug 

as 3 tlil-eatened species tliroughoot its range (72 FR 1064-1099); a final determination will be 

made following the ESA revicw process." 

On page 3-29. at the end of the first paragraph, Mass Slrandings. add the following sentences: 

"Tlicre were six polar hear mortalities in 2006. Mass walrus mortalities are occasionally 

reported Cape Pierce at Alaska in theTogiek terrestrial National haul-outs. Wildlife In 2005, Refuge. about Trampling 30 walruses deaths died have from hem tc~~ain reported Wlls at in the 

Punuk Islands near Sl. Lawence Island." 

4150 on page 3-2'). in the second paragraph under Human Inte~actions. add the following 

seiitcnces: "From 1996-2000. thc estimated mean mortality of walruscs from fisheries adivities 

u.as 1.2 walruses per year. Most human induced inofiality on the Pacific walruses 1s presently 

Croni legal suhsiste~ice hunting in Alaska and the Russian Federation (Chukotka). In 2005, the 

estimated total hunting removal of walruses from thc population was 5,276 animals " 

06/14/2007 2:36PM 
06/14/2007 15:03 2022086970 PEP PAGE 04/05 

2 

On page 3-29, line 13. Temporal Changes. add the following sentences: "Polar beasnd Pacific 

walrus strandings would be most likely attributed to changing sea icc habitat and could occur 

year round although thc most critical times for polar bears would probably be the spring soon 

aftor cubs are born thmugll the Call. For Pacific walrus the critical time for young animals and 

calves aodd be during the late spring-early summcr when rile females and calves follow the ice 

pack north." 

Also, on page 3-29, llne 211 Marinc Mammal Population Changes, add tke Jollowlng sentences: 

"The size and trend of the Pacific walrus population are currently unknown Population point 

estimates from1975-3990 ranged between 202.039 to 246,360 walruses, but were not precise 

ellough to accurately reflect trend TRe Southern Beaufort Sea Population and ChukchiiBering 

Seas populations of Polar bear are thought to be declining." 

On page 3-30, ensure that ~igurc 3-12. Alaska Region Pinniped Strandings 20012004. includes 

the strandings of Pacific walrus^ 

Appendix C-Policies and Best Practices for Marine Mammal Strandine Response, Rehabilitation, 

-- and Release. The NMFS coordinated with U?E FWS to compile the Standards for Release 

Gugdelines that are a part of these policies and practices The FWS provided comments 

throughout the dcvclopment of these Guidelines and we appreciate that they have been 

i?colporated in the January 2007 version. No further comment is necessary at this time: 

however. we do have some editorial suggestions. 

On page 2-1. under 2.1 .I NMFS Policies, last sentence, delete "with" so the sentence reads: 

"Hnuever. authotization to take ESA listed spccics by the Stranding Network is cl~rrenlly 

provided undcr h!hfPA/ESA permil #932-1489-01 as amended and requires authorization and 

dircction from witb NMFS Regio~~u! Stnnding Coordinator ill the event ol a stranding involving 

a threatened or endangered masine mammal." 

On page 2-3. o facility may also request permanent placement under Section 104(c)(3) i.Tan 

ESA-listed marine mammal is determined u~lr eleasable. Please edit the last paragraph on this 

page to reflect such: 

"For FWS spectcs. LOA and permit 11oIde1-s provtde recommendations to the FWS Field 

Oftices foi decisions regarding releasability of rehabilitated marine mammals (see 

Appcnd~x H for contact ~nlormation). The FWS retains the authority to make the ha1 

determination on the disposition ofthese animals. If FWS determtnes that a marine 

mammal i:; non-rclcasable, the holding facility may request a permit for permanent 

placement in captivity as prescribed in Scction 104(c)(7) ofthe MMPA for non-depleted 

species, or Section 104(c)(3) or 104(c)(4) and Section I@(a)(l)(h) of the ESA for 

depleted spccies." 

On page 5.1. ondcr Guidelines for Release of Rehabilitated Manatees. Introduction. second 

paragraph. the third and fourth sentence should read. "All rescue-related comniunicatioi~s and 

the day to day decision making process in the field are generally handled by the local 5ald 

06/14/2007 2:36PM 

06/14/2007 15:03 2022086970 PEP PAGE 05/05 

3 

Stations of the Florida Fish and Wildl~fe Conservat~on Com~niss~on (FFWCC) ~n conjunction 

with reports from the public using the 1 -888-404-FWCC hotline. All activioes related to 

verllicatton of a repoit of a manatee in trouble, subsequent rescue, and transport to rehabilitation 

facilities arc con~n~unicated through the FFWCC Fleld Staztons, according to established 

protocols." 

Acvendix E-Biological Resources Tables In Toblq El7. Marine Mammals Common inthe 

NMFS Northwest Region, the northern sea otter is identitiad as "threatened under the U.S. 

Endangered Species Act (ESA) However. the northcrn sea otter stock that occurs in this area, 

1.e. Washington Stat% is not listed as endangered or threatened under the ESA. 

In Table E-18, page E-30, Marine Mammals Common in Ule NMFS Alaska Region, the 

distribution ibr tlie Pacific walrus should read: "Found in shallow water areas, close to ice or 

land: geographic range is mainly in the Bering Sea and Chukclit Sea Ice pack." 

In :~ddition, on pagc E-3 1. tlie northern sea ottcr is identified as 'Yhreatened under the ESA 

Although this is correct fnr the southwest Alaska distinct population scgmcnt, neither the 

southcentral nor the southeast DPS is listed under thc ESA. 

Also, under Table E-18, we reconlmend including the Polar bear (Mrsi~s marilimvsjas a year 

round resident of die Arctic Circle. 

Aupendix L-Mxine Mammal Oil Soill Resuonse Guidcl~nes. On page 4 undcr Trustee 

Organizations. thc fifth sentence reads: 

"The Marinc Mammal Protection Act (MMPA) prohib~ts the "take" of sea otters. seals, sca 

lions. walmscs. a-hales. dolphins. and porpo~ses, which includes harassi~~g or disturbing these 

animals as well as actual harming or killing. . ." To avoid potential misundersrandings, we 

suggest including manatees and polar bears in the list oi'marine mammals for which the MM~A 

prohibits take. 

06/14/2007 2:36PM 
Fran transcript

T: Sure.ken.)T: Our court reporter will bents. Also, your written commentsay. You can hand them in today. Weeets up front that you can write on,em to us by mail or e-mail. Ihe handouts -- we also have ourto send them to. We just ask foromments, that you bring verygarding the content of the drafte suggest civic changes to

mental consequences that NMFS should

S: You want a written response in?T: No. If you just want to giveIf you think of something that youcan feel free to write it down.

w that additional information is also

14

 libraries, and it's available onIf you comment today, you will get acument. But if you're not

want a copy, please feel free to

-in sheet if you would like one. WeS: This is Peter Folkens from theion. I have four specific items to

Page 13

San Fran transcript

 9 raise. 10 First one pertains to the recognition of 11 stranding agreements across regions. Due to an ongoing 12 research affiliation at University of California, Davis, 13 a number of Alaska Whale Foundation personnel went over 14 into the San Francisco Bay Area from October to May. 15 We keep two of our six boats here as well. 16 They are assigned at the moment to Contra Costa County 17 Search and Rescue team. In southeast Alaska, we now see 18 more whale entanglements in one season than the 19 southeast region has experienced in a decade. 20 The Alaska Whale Foundation boat, 21 disentanglement equipment, and expertise can be put to 22 good use in Northern California. However, in a recent 23 Alaska stranding network meeting in Anchorage, it was 24 pointed out that stranding agreements are not recognized 25 across regions. 15 1 Under the notion of best practices, we 2 recommend that the National Marine Mammal Health and 3 Stranding network implements a policy and procedure to 4 either recognize stranding agreements across regions or 5 issue additional stranding agreements to singular 6 organizations that typically cross multiple 7 jurisdictions. 8 Item 2. Since the 9/11 and Katrina disasters, 9 the federal government has implemented policies and 10 procedures for the standardization of roles and training 11 levels of responders. This has taken the form of the

Page 14
Fran transcript

 response management protocols forl responses. I understand theeries Service employees are trainedt Alaska Marine Mammal

work meeting in Anchorage, the

about ICS training. It turns outendance except one has had ICS 100so mentioned by Robert Mahoney fromnchorage that the disentanglement facto NMFS kind of structure. It'sn ICS 100 structure be officiallyment responses across regions.n a related issue, responder typing

16

tate levels is a 1 to 4 hierarchyhest certification. However, theeries Service disentanglementping is backwards with 1 being thening. Since such responses oftenst Guard and other officialthat follow the other ICS and NMFSrecommend that National Marineips its type numbering so that 1 is with perhaps a 1A designation for responders.or many years, the standard training

was one from the Smithsonian

 by comparative anatomists. As the

Page 15

San Fran transcript

 15 Marine Mammal Protection Act and National Fisheries 16 Office of Protective Resources began to play a bigger 17 role in such events, the response data forms became 18 heavily focused on soft tissue sampling, probably 19 largely due to expertise of the veterinarians that were 20 taking major positions at the federal level. 21 Unfortunately, this was at a near-complete 22 disregard for anatomical and morphological data. Here I 23 requested the National Marine Fisheries Service 24 incorporates more anatomical data on its Level A data 25 form. Towards that end, I have offered a couple of 17 1 solutions that meet the needs of both the soft tissue 2 collectors and the comparative anatomists. I have 3 copies here that I've given to a few people and I can 4 give for the official record. 5 To give you an example of a real world 6 situation in which a better data form would have saved 7 literally hundreds of thousands of dollars for the 8 government, I was involved as an expert witness in a 9 ship strike event in which if the original stranding 10 data were taken better and with a more forensic line and 11 morphological and anatomical data, it is unlikely that 12 there would have been litigation over that event, saving 13 literally hundreds of thousands of dollars both for the 14 government and the private sector. 15 So I feel very strongly that the Level A data 16 form needs to include more forensic, morphological 17 information. Are there any questions?

Page 16
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1/31/2008 1:58 PM

niilaq.org>

ame.state.ak.us

at may be in distress or out of its natural habitat not be disturbed

imal unless and until appropriated approvals have been received

y citizen of United States to touch or attempt to rescue any

ording should be boldly highlighted in the EIS. We also strongly

ave been rehabilitated into the wild. There is too much risk that

ses that the animals in the wild have no immunity to. Regulations

d marine mammals into the wild.

THIS PAGE INTENTIONALLY LEFT BLANK 
07 deis 

2/8/2008 10:36 AM

mmal stranding program of 3/07 deis

voices@mail.house.gov

ver spring md

e bit tardy and not protecting resources for far too long a time rs ago to have a good plan in place to protect marine mammals

jurisdiction over any animals since it is so focused on business

n the welfare of any animal. Profiteers and businessmen rule

used in this department. Overfishing is rampant in this

 and more and more and with no conception of saving or 

mgt policies of this agency. virtually every species is overfished 

ant work. its spending should be closely audited to eliminate all 

uld to to helping mammals in trouble. right now graft and 

dept as can be imagined in our wildest nightmares) is no help

es geological survey have to do with marine mammals? this is 

eanwhile animal protection groups are blacklisted and kept out 

 in corrupt washington dc bureaucracy.

ation of "incidental" killing and murder - the public comment is 

marine mammals. these permits to kill are approved l00% of the

 it is pro forma.

fishing nets. this must be stopped now. negligence of this 

dous.

d in fishing gears is NEVER truthfully reported by the 

ers instead carry guns to kill all marine mammals. we need 

 fish boats.

gotten much dirtier and unhealthful. water quality has also been

uted - not 27%. Sediment contamination in this area is poor -

owing the contamination that has gone on for the past sixty 

THING for a clean environment. size of NJ is in "fair condition" seems like a ludicrous 

ska native organizations to kill marine mammals NOT TO CO 

ve words so americans dont understand exactly what your are 

h practices that are harmful to marine mammals - that is 

does enough to act as a "surveillance" network.

public comment on peis for marine mammal stranding program of 3/07 deis 

2 of 2 2/8/2008 10:36 AM

4-6 tags do caues pain and infection and use of them should be severely restricted. that is not happening.4-10 - absolutely periodic review should be made to stay in the stranding network.4-13 - public continually wanred about pathogens. no appendix was affixed showing any such issue exists or hasexisted in last ten years. please advise why you are claiming.4-14 - this doesnt have to be a 300 pg book. there is far far too much repetition in writing this book.4-19 - dont touch the animal unles syou intend to help it. otherwise leave it alone.4-24 - it is illustrative that 300 right whales are such a small population. their efforts at reproduction will probably NOT be successful and this species will probably go extinct like so many many others. it is clear that allowngcommercial fish profiteers to use whale life threatening gear is ludicrous and should be stopped now.4-26 educated people on the west coast certainly can follow guidelines on how to disentangle a whale without "training".4-30 tags on marine animals severely disrupt their lives. the use of tags should be banned just about totally.4-32 - inescapable that critter cams represent severe drain on a creature's energy causing injury and possible death. how would you like to drag 30 to 50 lbs weight with YOU every day of your life? the cruel abuse of these animals by alleged "researchers" is far too frequent and given much too liberablly.4-33 using bleach to mark an animal - what crazy insane researcher is on the loose with that insane idea? ifthere is no evidence of infection from being hit by a blowgun - i think the research is not satisfactory here and believe infection can and does result. this old research from l992 seems wrong.the research from l993 on effects on mammal of biopsy should be redone by researcher accompanied by animal protection person. some statements saying animal is "unconcerned" seem like self serving statements of the researcher hoping it is so. so researchers can then continue their assault on these animals.. self servingstatements.4-36 the stupid negligent diversion of all animal life into usda, fws, dot, noaa is far too divisive. there should be ONE AGENCY DEALING WITH ALL ANIMALS LIVING IN USA, STAFFED BY ANIMAL PROTECTIONISTS, NOT STAFFED BY ANIMAL USERS AND ABUSERS.4-37 - FESS UP - WHAT DISEASES HAS THIS DEPT INITIATED WHICH RAN RAMPANT BASED ON VACCINES INJECTED INTO PERFECTLY HEALTHY MAMMALS.B. SACHAU15 ELM STFLORHAM PARK NJ079324-**************************************See what's free at http://www.aol.com.
Commenter 

Number Page/Line Section Comment NM

12 N/A Entire document

While we largely support the Proposed Alternatives within the PEIS, we believe that the document does not sufficiently consider response to reported individual animals from strategic/depleted stocks. Additionally it must increase mandates for thorough examination of carcasses for human interaction.

Response activities are including those from strefforts may be made fothreatened or endangeinteraction documentatiPEIS in Section 2.1.1.1handbook and data sheStranding Network and added as Appendix M.

11 Page 1-5 Section 1.2.2

Should the $4 million specific figure be dropped from the text? I wouldn't want it to look like that is the final figure and can never go up (or down).

On page 1-5, lines 15-1"NMFS was authorized members of the Nationarecovery or treatment oof data from living or descientific marine mammoperation costs. Since appropriated $4.0 milliototaling over $16.5 millistranding network memPrescott Grant Program which does state that thannual Congressional a21, the following text waon the Prescott Grant P1.3.2.4." 

Comments on the PEIS and Appendices

Specific comments on PEIS sections

Page 1
Commenter 

Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

24 Page 1-10, lines 17-22 Section 1.3.2.2

To be all inclusive, the Department recommends the following additions..."For import and export of marine mammal specimens, the MMHSRP may be required to have import and export permits, if the species is listed on the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) Appendix I, II, or III. The CITES permits for import and export are issued by the FWS and are required to import and export samples, parts, carcasses, or live animal species (for treatment or release) listed in the CITES Appendices. Species listed on the CITES Appendix I require both an import permit and an export permit be issued for international shipments. Species listed on CITES Appendix II only require an export permit, unless the importing country has stricter mesaures than CITES. The only marine mammal listed under Appendix III is the walrus, Odobenus rosmarus ; either an import permit or a certificate of origin is required for each international shipment of walrus specimens."

Text revised per comm

19 Pages 1-11 to 1-12 Section 1.3.2.4

In order to facilitate organizations meeting and maintaining Rehabilitation Facility Standards and all other standards and activities recommended in the preferred alternatives, I urge NOAA to continue and expand the John H. Prescott Rescue Assistance Grant Program. 

Acknowledged

17 Pages 1-11 to 1-12 Section 1.3.2.4

The Prescott Grants Program has accomplished a great deal to date, and its continuation is crucial to the continuation and improvement of national stranding response. 

Acknowledged

19 N/A Section 2 I fully support adoption of the preferred alternatives. Acknowledged17 N/A Section 2 I support the implementation of the preferred alternatives. Acknowledged

Page 2
Commenter 

Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

25 Pages 2-3 to 2-4 Section 2.1.1.3

Under the notion of best practices, we recommend that the National Marine Mammal Health and Stranding network implements a policy and procedure to either recognize stranding agreements across regions or issue addtional stranding agreements to singular organizations that typically cross multiple jurisdictions. 

Stranding Agreements one NMFS region. Strarecognized across regioAgreement states that, authorized under a Strathe stranding response response area or in anothe appropriate regionaCoordinator (s)." 

20 Pages 2-3 to 2-4 Section 2.1.1.3

Of great significance are Section 2.1.1.3 Stranding Agreement and Response Alternatives. We reject Alternative A1 and A5 primarily because the risk to public safety is too great. If trained authorized personnel do not respond to injured or distressed marine mammals the public will take matters into their own hands as we have seen in the past. We also reject Alternative A3 and A2 on the grounds that they lack standardization and guidelines for the national network. We endorse Alternative A4 and support NOAA in their goal to offer guidelines, minimum criteria and standardization for network participants. 

Acknowledged

12 Pages 2-3 to 2-4 Section 2.1.1.3

We believe that NMFS must respond to reports of all floating large whales, regardless of whether external signs of human interaction are noted on the carcass, but having due regard to the operational conditions that may limit or constrain such attempts. Vessel strikes are frequently determined by necropsy, and not by external signs of trauma and, according to Moore et al. 2004, post mortem examinations are necessary to ensure better understanding of mortalities that are due to human interaction. We believe that floating large whales should be retrieved and thoroughly necropsied with a draft necropsy report made available within 14 [working] days of when the carcass is examined. 

NMFS attempts to respcarcasses. However, rhampered due to availetc.), weather conditionThe condition of the carresponse. If a carcass untowable, a necropsy taken of ropes or line to possible) and other samfor genetics or other sc

Page 3
Commenter 

Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

12 Pages 2-3 to 2-4 Section 2.1.1.3

Because there are areas where beaching a carcass for necropsy is difficult, we recommend NMFS funds the research, design, and construction of a number of mobile necropsy stations or barges. These would be located along the length of the east coast, with sufficient funding available to allow for the stations or barges to be utilized thus ensuring these data are collected in all US waters and our knowledge increased. 

We have significant logregarding the number orequired to cover all of tfloating carcasses may geographical range and In addition, NMFS belielogistically feasible attefloating carcasses. 

17 Pages 2-3 to 2-4 Section 2.1.1.3

More centralized oversight and management of national stranding response, through Headquarters, would be beneficial. 

Acknowledged

12 Page 2-5 Section 2.1.2.2

We support Alternative B3 recommending that chemically euthanized carcasses are transported offsite. While this Alternative alleviates many of the concerns of bioaccumulation resulting from scavengers preying on carcasses, we also believe that NMFS must support research into methods of euthanasia which are both humane and environmentally safe. 

NMFS has funded resechemical euthanasia anthese methods (see Apthat there is still much tchemical euthanasia soSection 6 has been updresearch in the area of includes research regarchemical euthanasia so

25 Page 2-6 Section 2.1.2.3

We will need assistance with determining appropriate burial if other disposal is not possible. We also request assistance in ranking chemicals for toxicity levels if chemical euthanasia is used and in working with vet and zoo/aquarium groups in developing non-chemical, humane and user friendly ways to euthanize.

NMFS has funded resevarious methods of cheacknowledges that therhas been updated to inthe area of humane eut

4 Page 2-5 Section 2.1.2.2

Guidelines are also needed for euthanasia, particularly of large whales. Research should be funded to identify or develop methods of euthanasia that are humane, efficient, and pose minimum risks to human safety and environmental health. 

NMFS will work with strensure carcasses are dlocal, state, and Federa

Page 4
Commenter 

Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

4 Page 2-5 Section 2.1.2.1

"Other methods" of disposal, as listed above, should be further defined and a list of specific, approved disposal methods should be listed in detail. There is the potential for individuals or facilities to loosely interpret "other methods" as a means of disposal; for example, "composting" could be interpreted as burial at the stranding site, which contradicts the intent of the recommendation. The NAIB also recognizes the need to identify alternative disposal methods for non-euthanized carcasses. 

 Added text to clarify coalternative method of catransporting carcasses methods identified in Sethat have been utilized (incineration, renderingleaving onsite). 

17 Page 2-5 Section 2.1.2.2

It is important that chemically-euthanized animals not remain in areas where the chemicals can be released to the marine environment as the animals decompose. 

NMFS concurs with this 

9 Page 2-6 Section 2.1.3.1

Further, we believe that animals should not be taken into rehabilitation facilities if they are poor candidates for release. This has happened with some regularity with small cetaceans (i.e., neonates being taken in, animals missing or with necrotic body parts, seriously ill animals). It is also not clear that the protocol described in the DEIS and its appendices will prevent this current problem from occurring in the future. 

NMFS agrees that there decisionmaking regardiNMFS is planning to hoguidelines for making d(see Section 6). 

4 Page 2-7 Section 2.1.3.3 Public display of animals in rehabilitation should be investigated and defined. See Section 6, Cumula

public viewing of anima

4 Page 2-7 Section 2.1.3.3 Priority funding should be awarded to organizations that seek to achieve or exceed minimum standards. 

Stranding network orgathrough NMFS via the cProgram. The priorities yearly, but coming into standards has been anfunding. 

Page 5
Commenter 

Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

12 Page 2-7 Section 2.1.3.3

We generally support Alternative C3 which would implement improved Rehabilitation Facility Standards, but we also strongly believe that NMFS must be clear that the primary objective of the SA holder is to release or refloat an animal immediately from the stranding site and moving a stranded animal into a rehabilitation facility is a last resort. 

For single strandings, it an animal as it has likelunhealthy. Unhealthy alikely restrand. Single aeuthanized or taken to strandings, typically mobe refloated. All strandcase basis, and the onsmaking an assessment 

17 Page 2-7 Section 2.1.3.3

Implementing a minimum set of standards would help to improve care for the animals, and would improve the knowledge base for treatments.

NMFS concurs with this 

9 Page 2-8 to 2-9 Section 2.1.4.1

We are concerned that the stranding response program should make every effort to facilitate beach release of newly stranded animals. We have seen instances in which beach coordinators specifically instruct responders not to return small cetaceans to the water until all biological sampling that can be done is completed. This delay is returning them to the water may compromise the animal's condition. Releases in other countries (e.g., New Zealand) are usually accomplished expeditiously and they should be here as well, since most studies have indicated that mass stranded animals are generally healthy. It is not clear from the protocols described in the DEIS that this is the goal or priority. It should be.

For single strandings, it an animal as it has likelunhealthy. Unhealthy alikely restrand. For singeither euthanized or takmass strandings, typicmay be refloated. All stby-case basis, and the making an assessment for all stranding responexpeditious assessmenassessment, biological any animal refloated woidentification (tag) in ca

Page 6
Commenter 

Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

2, 3, 5, 8, 10, 

16, 22, 27 Page 2-8 to 2-9 Section 2.1.4.1 Eight commenters opposed any release of any marine mammals that have been rehabilitated into the wild in Alaska. 

Text has been revised ilines 10-18, to state: "Athe potential for disease ice seals (bearded, ringwould be implemented would not authorize resseals beyond the geogrthe purposes of rehabilwild. NMFS would revicase-by-case basis: 1) seals as part of an officseals in Bristol Bay, AKNative organizations (cdetermine the best posAfter consultation with t

evaluate this policy at achanges in the status ohabitat." The text is taNMFS to John Goodwin The letter can be found 

17 Page 2-10 Section 2.1.4.3

Obligatory follow-up monitoring, with timely dissemination of results, is needed to learn which rehab efforts are useful, and to explore the impacts of released animals on wild populations (e.g., Wells et al. 1999; in review a, in review b). Sample sizes from releases to date are generally to small to be conclusive.

Stranding network orgathrough NMFS via the cProgram. The priorities yearly, but telemetry sturehabilitated animals hapriority. Collaborative snetwork organizations tparticularly important.

26 Page 2-10 Section 2.1.5.1 We support an article addition to the SA on small cetacean and pinniped disentanglement. Acknowledged

Page 7
Commenter 

Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

25 Page 2-10 Section 2.1.5.1 It's my suggestion that an ICS 100 structure be officially part of the entanglement responses across regions. 

NMFS agrees and is wothe Incident Command disentanglement respontraining at a variety of rnetwork meetings and w

25 Page 2-10 Section 2.1.5.1

Since such responses [disentanglement] often include the U.S. Coast Guard and other official government entities that follow the other ICS and NMFS typing protocols, I recommend that National Marine Fisheries Service flips its type of numbering so that 1 is at the highest level with perhaps a 1A designation for specific right whale responders. 

NMFS is considering thdetermine if this type of confusion among disenranking criteria has bee

8 Page 2-10 Section 2.1.5.1

The level designation for responders (Levels 1-5) should be reversed to coincide with designations standard in the Incident Command System Structure (lower numbers respresent the higher risk/greater experience roles). This is a minor point that might help integrate disentanglement response with other agencies' ICS response efforts. 

NMFS is considering thdetermine if this type of confusion among disenranking criteria has bee

12 Page 2-12 Section 2.1.5.3

We fully support Alternative E3 which would require the West Coast Disentanglement Network to adhere to the training standards and techniques currently employed by the East Coast Network. 

Acknowledged

17 Page 2-12 Section 2.1.5.3 Every effort should be made to ensure proper training and maintenance of standards for operations. Acknowledged

9 Page 2-12 Section 2.1.6.1

It is imperative that research undertaken or funded by the federal government adhere to standards of the Animal Welfare Act and that government agencies uphold the same standards required of other institutions engaged in research (i.e., IACUC oversight and adherence to IRAC principles). The DEIS should contain an explanation of whether and how the federal government is complying with these standards and if its research does not have this type of oversight and adherence to standards, why not.

NOAA-wide policy for thduring scientific researcOnce the NOAA policy conducted under the Mapproved by the anima

Page 8
Commenter 

Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

12 Pages 2-12 to 2-13 Section 2.1.6.2

While the Preferred Alternative F3 appears the most appropriate, we believe that the number of take permits on wild populations should be minimized and suggest that NMFS establish a sampling archive bank for unused protion of tissue, fecal matter, exhalation, fluids, etc. obtained by stranding networks. Future permit requests requiring these types of samples should be required to utilize archived materials prior to authorization of additional takes from the wild. 

The NMFS Office of ProConservation and Educwild populations of marissuance of permits. Thbank for toxicology samserum. Individual facilitsamples taken from straencourage the Permits these resources for the

17 Page 2-13 Section 2.1.6.2

In order to optimize the value of this research, it is important that a set of standardized diagnostic laboratories be identified or established that will allow for consistent sample analyses, and will be able to expeditiously handle the large number of samples that may result from a research program of Unusual Mortality Event investigation, for example. 

NMFS acknowledges thof standardized diagnoscurrently are no standaavailable for marine maOther logistical challengpresent time. 

9 Page 3-13 Section 3.2.2.6

There is a statement made on page 3-13 that "[o]f the livestranded small cetaceans, few are taken into a rehabilitation facility and very few are released." The wording in this sentence should clarified. It is not clear whether this sentence means to inform readers that, of the animals taken into rehabilitation facilities, very few are released; or whether it is stating that few are taken into rehabilitation facilities and, of the remainder who are not, "very few" stranded small cetaceans are released alive from the beach where they stranded. Each of these quite different interpretations has implications that should be addressed in different ways by NMFS. If "very few" of those taken into facilities are released, then the NMFS program should address the reasons for this (e.g., are poor candidates being chosen, are facilites unable to cope with needs of wild caught animals, etc.) and remedy them. If it is the latter scenario (that very few are released from the beach and die or are euthanized if not taken into rehabilitation facilities) then we believe that this too should be addressed.

Text revised per comm

Page 9
Commenter 

Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

12 Pages 3-13 to 3-21 Section 3.2.2.6

We are concerned that animals may be taken into rehabilitation with the express intent of supplying a captive facility. Data presented by NMFS in this document appear to substantiate these concerns. For instance, section 3.2.2.6 states that "up to 50% of the rehabilitated seals and sea lions are released back into the environment" and "of the live-stranded small cetaceans, few are taken into a rehabilitation facility and very few are released." It is unclear as to what happens to the othe 50% of pinnipeds that are not released-are they retained as captive animals, euthanized or die in reahb? Similarly for cetaceans, it is unclear why "very few" are released. Figure 3-3, Cetacean Strandings Nationwide appears to demonstrate that there is a substantially higher number of cetaceans taken into rehab versus the number released. The document offers 

Text revised per comm

9 Pages 3-13 to 3-21 Section 3.2.2.6

We would have appreciated a brief discussion of the likely reason for discrepancies in release of animals shown in charts depicting the fate of stranded pinnipeds and cetaceans shown in figures 3-2 and 3-3 of this chapter and in regional sections such as 3-4 and 3-5. There are virtually no releases of cetaceans shown. If this means that virtually all stranded animals are euthanized, we question this approach. If the "released" portion of each column only refers to animals taken into facilities for rehabilitation and subsequently released, this should be made clear. Simliarly, if the "yellow" portion of the bar showing "alive" stranded animals includes animals that were returned to the water from the beach and thus not counted as "released," then it should be so noted, with 

Text revised per comm

12 Pages 3-17 to 3-18 Section 3.2.2.6

In section 3.2.2.6, subsection , Northeast Region- Human Interaction, the PEIS notes ship strikes to right whales but not to other species. While the issue of ship strikes is a significant contributing facto to the potential demise of the critically endangered North Atlantic right whales, all large whale species are at risk.

The following text was a

of Gulf of Maine humpbship strikes of Western from 2001 to 2005 in th2007). Ship strikes havsperm, sei, blue, and m

2003) "

Page 10
Commenter 

Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

12 Pages 3-18 Section 3.2.2.6

In the subsection, Northeast Region-Temporal Changes, it states that "ship strikes and entanglements are frequent in summer." While we do not dispute the accuracy of this statement, we do question why documented entanglements and ship strikes that occur outside of summer are not considered, and have been excluded. Documenting human interaction throughout the year is critical in determining whether seasonal exemptions, as proposed in management schemes, are sufficient or appropriate. 

Documented entanglembeen excluded. This seand ship strikes seem tNortheast Region. Entadocumented whenever 

11 Page 3-20, line 29 Section 3.2.2.6 Add striped dolphins to the list of mass strandings in the SER. Text revised per comm11 Page 3-21, lines 13-14 Section 3.2.2.6

I question the comment on page 3-21 that right whales and humpback strandings occur during the winter "migratory period from Nov-Apr." To begin that period described is six months long and therefore describes half of the year. Additionally, there is evidence from a number of aerial survey efforts off the mid-Atlantic and SE Atlantic Bight (reference documents as contract reports to the SER) of right whales and especially young humpbacks in the region from Sept to June. I would suggest some language like "southern component of their home range."

Text revised per comm

24 Page 3-24, lines 5-9 Section 3.2.2.6

We note that a UME was delared for southern sea otters in 2003. Unless this event is being lumped with the "Multispecies UME" for 2003, the 2003 southern sea otter UME should be included in this paragraph. 

Text revised per comm

24 Page 3-28, line 1 Section 3.2.2.6

...including the polar bear, there are twenty-nine marine mammal species that have the potential to occur in the Alaska Region. 

Text revised per comm

24 Page 3-28, line 4 Section 3.2.2.6

...insert the following sentence on line 4 before the sentence beginning with "Endangered species include...": "On January 9, 2007, the polar bear was proposed for listing as a threatened species throughout its range (72 FR 1064-1099); a final determination will be made following the ESA review process."

Text revised per comm

Page 11
Commenter 

Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

24 Page 3-29, line 3 Section 3.2.2.6

...add the following sentences: "There were six polar bear mortalities in 2006. Mass walrus mortalities are occasionally reported at Alaska terrestrial haul-outs. In 2005, about 30 walruses died from terrain falls at Cape Pierce in the Togiak National Wildlife Refuge. Trampling deaths have been reported in the Punuk Islands near St. Lawrence Island."

Text revised per comm

24 Page 3-29, line 11 Section 3.2.2.6

...add the following sentences: "From 1996-2000, the estimated mean mortality of walruses from fisheries activities was 1.2 walrus per year. Most human induced mortality on the Pacific walruses is presently from legal subsistence hunting in Alaska and the Russian Federation (Chukotka). In 2005, the estimated total hunting removal of walruses from the population was 5,276 animals."

Text revised to include: mean mortality of walru1.2 walrus per year." Tadded because the secinteractions that are not 

24 Page 3-29, line 13 Section 3.2.2.6

...add the following sentences: "Polar bear and Pacific walrus strandings would be most likely attributed to changing sea ice habitat and could occur year round although the most critical times for polar bears would probably be the spring soon after cubs are born through the fall. For Pacific walrus the critical time for young animals and calves would be during the late spring-early summer when the females and calves follow the ice pack north."

Text revised per comm

11 Page 3-29, lines 14-21 Section 3.2.2.6 Why is there a specific section on "marine mammal population change" only for the Alaska region? Marine mammal popula

for each of the NMFS re

24 Page 3-29, line 21 Section 3.2.2.6

...add the following sentences: "The size and trend of the Pacific walrus population are currently unknown. Population point estimates from 1975-1990 ranged between 202,039 to 246,360 walruses, but were not precise enough to accurately reflect trend. The Southern Beaufort Sea Population and Chukchi/Bering Seas populations of Polar bear are thought to be declining."

Text revised per comm

24 Page 3-30 Section 3.2.2.6 ...ensure that Figure 3-12, Alaska Region Pinniped Strandings 2001-2004, includes strandings of Pacific walrus.

Stranding information lipinniped species. Texlines 22-26 to state that excludes walrus.

Page 12
Commenter 

Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

11 Page 4-8 Section 4.2.1.2

Direct cardiac injection of euthanasia solution on sedated animals has proven to be effective and relatively safe for the responding team. 

Acknowledged

11 Page 4-23, lines 8-12 Section 4.2.4.3

Although the DEIS specifies (pg 4-23, lines 8-12) that release criteria would include a "medical assessment with a a handson physical examination and a review of the animal's complete history, diagnostic test results, and medical and husbandry records," these precautions can only minimize the risk, not eliminate it. Testing is not possible for new diseases as tests are not developed until the disease is known. Many tests used for marine mammals are developed for domestic animal use and the effectiveness for marine mammals is not known. False negatives from these tests are common.

NMFS acknowledges threleasing animals. Howminimize this risk. The criteria will not eliminate rehabilitated animals. 

12 Page 4-24 Section 4.2.5.1

We are concerned, however, that in Section 4.2.5, NMFS indicates that "North Atlantic right whales would be greatly affected if disentanglement efforts ceased, as entanglements are know to be a significant source of mortality." While we support the disentanglement program, we do not support the notion that this is an appropriate solution for right whale entanglements. Disentanglement is, at best, a stop-gap measure and should not be viewed as responsible or appropriate mitigation when other risk mitigation measures have already been held up for a number of years. 

NMFS agrees that disesolution to reduce large measures to reduce enactivities of the MMHSR

11 Page 4-25 Section 4.2.5.2

I would like to commend the statement regarding potential injury to entangled animals may be intentional by responders. I believe strongly that we need to be developing more invasive techniques for working with life threatening entanglements. A small injury to the animal, say a quick tissue cut, should not stop teams from going in and actually cutting heavily entangled animals. The faster gear can be cut loose, the better the potential outcome for the animal. 

NMFS concurs with this 

Page 13
Commenter 

Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

10 Page 4-47 Section 4.4.4.3

In considering the effects of the release of rehabilitated marine mammals on cultural resources (Section 4.4.4.3, pg 4-47) we believe you need to consider the ability to obtain marine mammals for food, boat covers, rope, clothing, artwork, and cultural objects could be severely affected by the release of a rehabilitated marine mammal that carries an undetected disease or parasite that infects wild populations. 

NMFS believes that this to occur given the curreRelease Criteria) and it releasing the animal. 

12 Page 4-60 Section 4.6.3.3

Furthermore, while we acknowledge that, as stated in 4.6.3.3, the cost to facilities resulting from upgrades necessary to meet new standards may be significant, we do not support the proposition that these additional funds can be raised by allowing these facilities to charge visitors to view animals in rehabilitation.

Nowhere in the draft PEfor upgrades could be afor, public viewing of andocument specifially stafunds are the main meaupgrading rehabilitation document does mention as a future activity in Seassessment of environma decision would be ma

10 Page 4-61 Section 4.6.4.3

In considering socioeconomics (Section 4.6.4.3, pg 4-61) we believe you need to consider the cost to families in coastal Alaska if they cannot obtain food from the marine mammal resources and must purchase it in local stores. Food costs are extremely high in remote villages due to fuel costs for air transportation.

NMFS believes that this to occur given the curreRelease Criteria) and it releasing the animal.

9 Page 5-2 Section 5.2.1

...NMFS should provide general guidance on situations or types of animals who are clearly not good candidates for release and should be considered for euthanasia and/or when animals might be released from the beach rather than euthanizing them. This sort of guidance has been lacking and has led to situations in which animals that were clearly poor candidates for release were taken into rehabilitation facilities, necessitating the expenditure of resources for their ultimately unsuccessful care or to find placement for non-releasable animals. 

NMFS agrees that there decisionmaking regardiNMFS is planning to hoguidelines for making d(see Section 6). 

Page 14
Commenter 

Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

9 Page 5-2 Section 5.2.1

Mitigation for tagging, described under this chapter's alternatives, as well as in the permit in Appendix G and H should include a stipulation that the tags being used should be the smallest and least intrusive available that has been proven effective to meet the purpose.

Any mitigation for taggiPermits, Conservation athe new ESA/MMPA pe

9 Page 5-11 to 5-12 Section 5.2.6.2

Further, there should be a stipulation that if any death occurs during capture or tagging of animals, research should be halted pending review by experts as to the reason for the mortality and to recommend means of avoiding additional mortality.

Any mitigation for capturesearch activities, wouPermits, Conservation athe new ESA/MMPA pe

9 Page 6-1 Section 6.1.1

Section 6.1.1 and Table 6.1 discuss the possibility of amending regulations under the MMPA to allow public viewing of animals being rehabilitated. Although we understand the utility of raising this possibility in the DEIS, we would strongly oppose such a measure if it is raised in the future. 

NMFS published an AdRulemaking (January 3the need for modificatio

15 Page 6-3 Section 6.1.1

Contrary to the statement in the DPEIS, the cited regulation (50 CFR 216.27(c)(5)) does not establish a complete prohibition on the public display of marine mammals undergoing rehabilitation. Rather, such displays are not allowed unless the Regional Director or the Director of the Office of Protected Resources has specifically authorized them and unless they are conducted in a manner consistent with the requirements applicable to public display. This being the case, regulatory changes are not needed. 

Text revised per comm

Page 15
Commenter 

Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

15 Page 6-3 Section 6.1.1

Elaborate on the Service's plans for developing draft guidelines to govern when public display of marine mammals undergoing rehabilitation will be authorized, including opportunities for the Commission, the affected facilities, and the public to review the draft guidelines before their adoption.

Text revised as to stateguidelines that govern wrehabilitating marine maNMFS would work with guidelines that ensure tthe Animal Welfare Act designed to protect animpotential for a successfcompromised. At a minto assess any impacts aguidelines. The guideliby the MMC, current republic."

15 Page 6-3 Section 6.1.1

The Marine Mammal Commission therefore urges the National Marine Fisheries Service to work closely with the Animal and Plant Health Inspection Service in developing the guidelines for public viewing to ensure that the requirements of the two statutes are met and that the potential for successful rehabilitation is not compromised. 

Text revised as followsdevelop public viewing requirements of the MMare met. The guidelineanimal health and to ensuccessful rehabilitation 

26 Response, Rehabilitation, and Release We support close coordination between HQ and the regions when evaluating SAs, rehab centers, and releases. There should be cross regional consistency whenever possible. Acknowledged

15 Response, Rehabilitation, and Release

Discuss alternatives for addressing overcrowding at rehabilitation facilities, issues associated with the placement of non-releasable marine mammals in public display facilities, and criteria for making on-site evaluations of the likelihood that a stranded marine mammal can be successfully rehabilitated and released. 

Rehabilitation facilities capacity for their facilityrequirements listed in thStandards. If facilities amay be tranferred to othOvercrowding of pinnipby watching animals to stranded before picking working with the PermitDivision to streamline areleasable marine mamNMFS' plan to hold a w

process to decide if an 

Miscellaneous Comments

Page 16
Commenter 

Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

15 Euthanasia Clear and specific standards also are needed for determining when euthanasia of a stranded animal is appropriate. The attending veterinar

determining when euthaappropriate and the mo

26 109h We suggest that 109h holders be held to similar criteria as SA holders are. Acknowledged

25 Level A form

Here I request the National Marine Fisheries Service incorporates more anatomical data on its Level A data form. Towards that end, I have offered a couple of solutions that meet the needs of both the soft tissues collectors and the comparative anatomists. (See copy of form). 

This data is Level B or develop a standard form allow it to be entered indatabase. 

12 Human Interaction

We also believe that while all species should be checked for signs of human interaction, it is particularly critical that strategic and/or depleted stocks be thoroughly examined for signs of human interaction (e.g. necropsy rather than external examination only).

Information on human iadded to the final PEIS interaction handbook anCape Cod Stranding Newas also added as Appconducted on animals wfeasible, however, everphotographs and sampAnimals are examined fregardless of the status 

9 Human Interaction

The DEIS does not discuss in detail what investigation should be undertaken to determine whether human interaction has occurred nor how best to document it in dead animals....Some specificity might be provided with regard to standards for accurate determination and documentation of human interaction.

Information on human iadded to the final PEIS was also added to Sectinteraction handbook animplemented.

9 Funding

Finally, we are concerned with unfunded mandates. The NMFS must assure that it requests adequate funding to ensure that the standards of stranding response and rehabilitation are uniform and sufficient to the important task laid out in portions of the DEIS.

The Office of Managemrequests to Congress foincluding NMFS. 

Page 17
Commenter 

Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

15 Unusual Mortality Events

Revise the DPEIS to provide an update on the status of final reports of unusual mortality events, explore ways to promote completion and circulation of final reports more promptly, and identify actions that the Service can take to improve the synthesis and use of data from unusual mortality events. 

Additional information ofinal PEIS (including nudetermined). Howeverappropriate place to disor how to improve the sUMEs. This is an admiaccomplished outside o

17 Appendix C Entire document

I am very supportive of the development and implementation of the "Policies and Best Practices Manual" as described...Such a package of standardized policies and practices will help to elevate the quality of efforts of the entire network, will increase the value of the information resulting from these activities, and will improve the return on investment [of] the Prescott Grants Program, for example. 

Acknowledged

7 Appendix C- Disentanglement

PCCS encourages that two certified national training centers, one on the Atlantic coast and one on the Pacific coast, be established to accomplish the goal of implementing the national standards and guidelines. Having clearly designated certified training centers will greatly facilitate implementation of standardized training so that the full benefits to human safety of Alternative E3 can be realized. Training would not occur exclusively at these training centers; rather those conducting disentanglement training would come from the certified training centers. This model has proven to be very effective on the Atlantic coast where PCCS has hosted trainees in an apprenticeship program and also sent staff to train Network members at various locations. 

NMFS is looking for watraining. 

Comments on Appendices

Page 18
Commenter 

Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

7 Appendix C- Disentanglement

The training video referred to in Level 1 and 2 criteria was created by PCCS specifically for distribution to U.S. Coast Guard stations to present Level 1 information to Coast Guard personnel. While much of the information is still relevant and accurate, the video is somewhat dated. Viewing this video is not a substitute for on-water experience or training and should be deleted as an "or" criteria listed for Level 2 certification.

NMFS agrees that the vfor on-water training. Ththe training tools and is qualifying Level 1 and 2 NMFS will work on upd

Definition of criteria for certification should be improved. Requiring completion of Level 1, Level 2, and Level 3 classroom or on-water training without some indication of the objectives of the training is vague. It should also be recognized that some people have extensive skills and experience that is applicable. We suggest the following objectives be incorporated to help clarify the criteria:Level 1- Level 1 classroom training covers definition of entanglement with examples, information on species usually involved, need for standby, documentation, overview of basic assessment and disentanglement objectives and techniques. Level 2- Documented whale experience or at-sea training, including species and individual ID, visual tracking (standingby), disentanglement operation protocols, basic understanding of equipment (including telemetry, and disentanglement strategy.Level 3- Demonstrated understanding of Network protocols and authorizations. Demonstrated understanding of, and ability to use, specialized tools including telemetry equipment. Demonstrated understanding of disentanglement strategies, planning, and techniques. 

7 Appendix C- Disentanglement NMFS appreciates thes

incorporating the sugge

Page 19
Commenter 

Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

7 Appendix C- Disentanglement

There are inconsistencies between the responsibilities and certification criteria for some of the Levels. For example, Level 2 personnel are tasked to "provide a thorough assessment of the nature of the entanglement and the species, condition and behavior of the whale," but specific knowledge of species ID and behavior is not required until Level 3 certification. The Level 2 criteria suggested above should help rectify this discrepancy. 

NMFS appreciates thesincorporating the sugge

7 Appendix C- Disentanglement

Level 3 responders may be authorized to disentangle whales under supervision. We suggest striking the words "a minor entanglement with potential to adversely affect" in the last bullet point under responsibilities for Level 3 responders. The bullet point would then read: May be asked (depending on experience) to disentangle any whale other than right whales under the supervision/authorization of Level 4 or 5 network members. Authorization and supervision may be given over the phone or radio depending on the circumstances and level of experience.

NMFS appreciates thesrecommendation. 

24 Appendix E, page E-29 Table E-17

...the northern sea otter is identified as "threatened" under the U.S. Endangered Species Act (ESA). However, the northern sea otter stock that occurs in this area, i.e., Washington State, is not listed as endangered or threatened under the ESA. 

Text revised per comm

24 Appendix E, page E-30 Table E-18

...the distribution for the Pacific walrus should read: "Found in shallow water areas, close to ice or land; geographic range is mainly in the Bering Sea and Chukchi Sea ice pack."

Text revised per comm

24 Appendix E, page E-31 Table E-18

...the northern sea otter is identified as "threatened" under the ESA. Although this is correct for the southwest Alaska distinct population segment, neither the southcentral nor the southeast DPS is listed under the ESA.

Text revised per comm

24 Appendix E, page E-31 Table E-18 ...we recommend including the Polar bear (Ursus maritimus ) as a year round resident of the Arctic Circle. Text revised per comm

7, 8, 25 Appendix F- Disentanglement No need to list names of Level 1 and 2 responders Text revised per comm

Page 20
Commenter 

Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

14 Appendix H Entire document

This appendix could use an up front description/summary of how this information should be used in the stranding context (versus the research context).

Appendix H is a descripmethodologies used by ESA/MMPA permit. Whresponse activities for Ecover basic methods us

14 Appendix H Entire document

At points, this document seems to refer only to one taxon or species in many places without specifying which and then does not discuss the other taxa/species. Bottom-line, it is not always clear what species is being included and if all other species are excluded. 

Information throughtout specify if it refers to cet

14 Appendix H, Page H-1 Section 1.1.2 and Section 1.1.3 Sections 1.1.2 and 1.1.3 are not typical activities for a stranding organization.

Appendix H is a descripmethodologies used by ESA/MMPA permit. Ac1.1.3 are used by these been used during stran

14 Appendix H, Page H-2 Section 1.1.4

The first sentence reads: Capture of marine mammals may be necessary during research activities to collect specimens, perform an examination, or attach tags or scientific instruments. This appendix should address stranding scenarios, not research, or there should be a pre-amble to discuss how it applies in stranding situations. 

Appendix H is a descripmethodologies used by ESA/MMPA permit. Whresponse activities for Ecover basic methods us

14 Appendix H, Page H-4 Section 1.1.4 Chemical restraint should require veterinary input. 

Text added in first parawould be performed or personnel and, if possibmammal veterinarian wprovide direct on-site suthe use of anesthesia a

14 Appendix H, Page H-5 Section 1.1.5 Sedation of large pinnipeds should require veterinary input.

Text added to state: "Se

be performed or directly and, if possible, an expveterinarian would be pdirect on-site supervisio

of sedatives "

Page 21
Commenter 

Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

14 Appendix H, Page H-7 Section 1.1.6 Instruments should be attached to the coat of the animal, not to the skin. 

Text revised to clarify thattached to the skin : "A used to glue scientific inpinnipeds. "

14 Appendix H, Page H-8 Section 1.1.7 Restrictions concerning hot branding should be specifically addressed. Text revised to state: "H

be conducted during th

22 Appendix H, Page H-8 Section 1.1.7 Therefore, we do not support any freeze branding or marking of any marine mammals in coastal Alaskan waters. 

NMFS encourages the generally non-invasive an adhesive) for post-reAlaska, freeze branding rehabilitated animals reCenter. Satellite tags aby the Center for post-rInvestigators listed undpermit do not engage in 

14 Appendix H, Page H-10 Section 1.1.9 The second paragraph refers to dolphin biopsy sites. What about other cetaceans and pinnipeds? Additional information w

sampling of cetaceans 

14 Appendix H, Page H-10 Section 1.1.10

Some folks prefer 19G or even 20G, some prefer butterflies to straight needles. A 4cm needle is longer than needed for some sites/animals and may be too short in some cases. Recommend this be changed to read "of appropriate size."

Text revised to state: "Nsampling is dependent 

14 Appendix H, Page H-11 Section 1.1.10

Again, I would leave the precise needle size up to the discretion of the veterinarian. The extradural vessel is not a sampling site in otariids. Otariids and some phocids can be sampled from flipper web veins. 

According to Geraci anvessel is a sampling sitinclude flipper web veinand phocids.

14 Appendix H, Page H-12 Section 1.1.13

The second paragraph refers to extracting the #15 tooth of the lower jaw. What species is this for? Pre-molars are extracted in pinnipeds.

The tooth sampling metto small cetacean healtsampling methods for p

14 Appendix H, Page H-13 Section 1.1.13 Catheterization is also possible in pinnipeds. Text was revised to inc

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Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

14 Appendix H, Page H-13 Section 1.1.13

The fourth paragraph's last sentence reads: The samples are sent to a diagnostic laboratory for culturing and species identification. Does species refer to the parasite species? Prey analysis?

For health assessment diagnostic laboratories 

14 Appendix H, Page H-14 Section 1.1.13 Please site the source of the thermal probes. There are other deep rectal probes available. The thermal probes des

of probes that may be u

14 Appendix H, Page H-14 Section 1.1.13 In the last paragraph of Section 1.1.13, change brevetoxin to any toxin Text revised per comm

14 Appendix H, Page H-14 Section 1.1.14 Veterinarian involvement should be required. 

Text added in first parawould be performed or personnel and, if possibmammal veterinarian wprovide direct on-site suthe use of anesthesia a

22 Appendix H, Pages H-14 to H-15 Section 1.1.14

Another concern of the Bristol Bay Marine Mammal Council, the Qayassiq Walrus Commission, and Bristol Bay communities is researchers prescribing or injecting medication to marine mammals while in the field. 

Animals in the wild may activities, but would not Animals in rehabilitation they clear out of their syreleased. 

1 Appendix H Section 1.1.15

 First of all, I believe that it is an error to not include the mysticete cetaceans in the research measuring hearing that can be measured using evoked potential procedures. There has been a previous Marine Mammal Permit issued to Dr. Sam Ridgway allowing Auditory Evoked Potentials to be measured on mysticete whales, and to exclude this sort of research now cuts off a very important and necessary source of information on this group of animals. There is no apparent justification for excluding this group of animals and they should be included in future efforts to measure the hearing of whales using auditory evoked potentials.

Currently NMFS PermitDivision does not have procedures on mysticetbe used on mysticetes developed. Text has beprocedures would not bthere is no documentatbe successful in applyinmysticetes. AEP experare inherently difficult fomysticete anatomy pres

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Commenter 

Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

1 Appendix H Section 1.1.15

The first paragraph of 1.1.15 indicates that “sounds are presented through a jawphone attached to the lower jaw”. That method of sound presentation is not the best method. While we are assured that bottlenosed dolphins hear well through their lower jaw, (Mohl et al 1999), many other species of odontocetes may not use this same pathway. One can be assured that sound is traveling through the best natural path, and that sound can be best measured in the free field, if it is presented in the water around the animal rather than through a jawphone. Sound presentation to all odontocetes in all Auditory Evoked Potential experiments for stranded animals should certainly not be limited to a “jawphone attached to the lower jaw”. The lower jaw would also certainly not be the best place to present sounds to a mysticete.

Text has been revised tprocedures on odontochave been added, as nthem at this time.

1 Appendix H Section 1.1.15

The next sentence indicates that...”Recording, ground and reference suction cup electrodes are attached along the dorsal midline”. That is also not necessary or required. Most animals held in water do not require a ground electrode. Only two electrodes are necessary. A suction cup electrode attached to the dorsal fin is certainly an excellent place to secure it with a suction cup. There is little myogenic electrical noise within the dorsal fin.

Text revised per comm

1 Appendix H Section 1.1.15

Many odontocetes that have been examined hear frequencies from 1 to 160 kHz. Some, like the harbour porpoise and the white beaked dolphin, hear as high as 180 kHz (Nachtigall et al, 2000). Some mysticetes, because of the frequency of their emitted signals, are thought to hear as low as 20 Hz. The written range of “Frequencies used for testing range from 5 to 120 kHz” written in section 1.1.15 severely, and unnecessarily, limits the hearing range tests of cetaceans.

Text revised per commwas not added, as testithis time under the ESA

1 Appendix H Section 1.1.15

I do not believe that qualified scientists should be limited by the Auditory Evoked Potential guidelines currently presented in Section 1.1.15.

The guidelines presenteto researchers listed as ESA/MMPA Permit No. 

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Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

9 Appendix H, H-18 Section 2.1.3

The meaning of this is not entirely clear, but allowing the permit to be used to conduct auditory evoked potential studies on mysticetes should be considered a major amendment of the permit and require publication of the intent to amend the permit in the Federal Register with an opportunity for the public to comment on the methodology and magnitude of the research. 

Conducting auditory evmysticetes would be cothe permit. PR1 would in the Federal Register period. Section 7 consreinitiated if activities wspecies. 

9 Appendix H, H-18 Section 2.1.4

Section 2.1.4 states that the section on vaccination is not completed. The National Environmental Policy Act requires that reviewers be allowed to review and comment on all aspects prior to approval of any procedure. 

Section 2.1.4 was comppublished. The "[Sectiomistake. This section avaccination have been 

9 Appendix I

We do not see tables describing impacts of stranding response, other than the very general mention of Project I, which we assume to be emergency stranding response. All impact from possible activities are lumped together. We would expect to see greater detail for stranding response that included, for example, estimates of the number of animals taken by intentional lethal take (i.e., euthanasia) and numbers of animals projected to be taken into/transferred to permanent captive display.

The information in the tresponse is only for ESare covered under the pare not covered under tunder Stranding Agreemof the permit application Division (PR1). The tabto input from PR1. This when PR1 publishes a Register, which initiates 

9 Appendix I

With regard to the tables for the NMFS permit, we note in the table provided that 50 small cetacean animals would be subject to study with a requested mortality of up to 3 animals per year. This is 6% mortality for cetaceans, which seems high based on capture and study [release?]-related mortality observed in studies by Mote Marine Lab in Sarasota. Further 100 pinnipeds would be taken with a requested mortality of 3. This represents a mortality rate much higher than the rates projected for mortality under the Steller sea lion EIS and in other permits for study of pinnipeds. These mortality rates should be explained. 

These tables were part submitted to the NMFS tables have been reviseThis new information wpublishes a Notice of Rwhich initiates a 30-day 300 pinnipeds (annuallystudies were requested animals per year. Takerequested, with a requeyear. These take numbconducted on any pinnithroughout the U.S.

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Number Page/Line Section Comment NM

Comments on the PEIS and Appendices

24 Appendix L, page 4

...under Trustee Organizations, the fifth sentence reads: "The 

Marine Mammal Protection Act (MMPA) prohibits the "take" of sea otters, seals, sea lions, walruses, whales, dolphins, and porpoises, which includes harassing or disturbing these animals as well as actual harm or killing..." To avoid potential misunderstandings, we suggest including manatees and polar 

bears in the list of marine mammals for which the MMPA

This comment was pasMarine Mammal Oil Sp

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Number Page/Line Section Comment NMFS Respo

14 Page 1

Having a stranding agreement number would make it easier to reference, or please specify how this agreement should be referenced.

The Stranding Agreement template has header on each page containing the inforeference the agreement: the region, thname, and the period of effectiveness o

14 Page 1 Having an abbreviated (1page) version to present when transporting animals would be helpful.

The signature page of the template has of those articles authorized. Along with dates listed on this page, it can be taken summary of the Stranding Agreement. 

20 Page 3 Article II, section B

Article II section B lists the NMFS responsibilities. It would be helpful to the Stranding Agreement Participants to understand the experience level and qualifications of the NOAA employees in its region. Stranding Participants are all required to provide such information and it seems prudent the NOAA agree to do the same. 

In the revised document, NMFS responsection C. NMFS considers the experieMMPA both when hiring and contracting designating agents outside the agency. 

14 Page 5 Article II, section B Additional bullet for NMFS responsibility to read: 9. Coordinate regional activities to ensure appropriate division of responsibilities based on geography as well as institutional responsibilities. Text has been inserted as responsibility 

C.

14 Page 5 Article II, section C

What should an organization do if financial constraints require limiting its efforts? Financial difficulties can come up quite suddenly and may not permit the requested notification time for changing the agreement.

In the revised version, Participant respoSection D. Stranding Agreement particRegional Stranding Coordinator if they astrandings for any reason, including finaStranding Coordinator will request assisparticipants when practicable and necesArticle II C. number 10). NMFS and the to determine whether changes in the strtemporary, or merits a modification of th

Comments on the Stranding Agreement Template

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Number Page/Line Section Comment NMFS Respo

Comments on the Stranding Agreement Template

14 Page 5

Article II, 

section C, part 

4

Is an organization still allowed to request payment for reasonable recovery costs for samples transferred to authorized persons or labs?

(Article II Section D, part 4 in revision). may be reimbursed for shipping and othauthorized to receive samples collected mammals (marine mammal parts may nconsidering changes to the regulations 2008) that may clarify the language regrecipients for services and transportatiotransferring stranded animal samples o

13 Page 5

Article II, 

section C, part 

4

While the participant organization is responsible for most costs incurred during a stranding event, this responsibility is unfair and impractical in the case of an Unusual Mortality Event. Sampling protocols are extensive during a UME and shipping costs to diagnostic labs can be an encumbrance to an organization. NMFS must, not may, support costs associated with UMEs, particularly supplies and shipping and diagnostic costs. A pot of money should be set aside to provide monetary support for UMEs around the country. It is unlikely that a Prescott grant could cover additional costs associated with a UME. 

(Article II Section D, part 4 in revision). authorized, NMFS will continue to suppspecific analyses and additional requesMortality Events (in accordance with MMMortality Event National Contingency Fufunds is reserved from the annual Prescmake emergency assistance available fevents throughout the year on an as-nesuch stranding events should immediateOffice. Because both of these funding sannual Congressional appropriations, th

20 Page 5

Article II, 

section C, part 

4

Article II, section C, part 4 states that the stranding participant shall bear any and all expenses incurred with the taking, collection, or other activities pursuant to this agreement. NMFS may be able to support costs associated with specific analysis and additional requests as funds are available and authorized. This section should clarify that these activities do not include the towing of large whales. We also suggest that the language reflect the fact that activities will be based on the financial resources of the Stranding Participant. If the Stranding Participant does not have the resources available then the samples cannot be collected, shipped, or analyzed. Language used in the NMFS responsibility section such as “as resources are available” would be appropriate here.

On occasion, NMFS has financially asswhale carcasses (particularly North Atlalanguage in Article II, C 4 (Article II, D.4modified to state that the Participant wilresponse, rather than bear the cost of thcannot be managed by the Participant sdata collection responsibility for level B B. 2. b.) has been modified to include thlanguage. 

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Number Page/Line Section Comment NMFS Respo

Comments on the Stranding Agreement Template

13 Page 8

Article III, 

section B, part 

1a

If NMFS is going to implement the ICS structure in certain circumstances and expect the responding stranding organization to follow that structure, then NMFS needs to provide ICS training to all participants. 

Regional stranding coordinators will be information regarding ICS training oppohave not received specialized training. websites with online training for ICS (e.ghttp://training.fema.gov/IS/)

13 Page 9 Article III, section B, 2 a

The need for completed data such as Level A form is imperative, however, having a set schedule for when the data are due is a cause for concern. A set schedule suggests rigidity and does not allow for flexibility for organizations that have limited available personal or mitigating circumstances. It is a concern that organizations will be penalized if this inflexible schedule is not met. 

Implementation of the MMHSRP requiredata. Title IV of the MMPA, for exampleeffective response to Unusual Mortality occurring in multiple stranding response rapidly without timely reporting, precludMost participants are able to provide rephave received Prescott funds to improve reporting abilities. NMFS personnel havparticipants that periodically have troubdeadlines. 

13 Page 9

Article III, 

section B, part 

2 c

The ability to contact NMFS [Region] Regional Stranding Coordinator when there is a possible or confirmed human interactions, suspected unusual mortalities, extralimital or out of habitat situations, mass strandings, mass mortalities, large whale strandings, and any other involving endangered or threatened species of concern within 24 hours seems to be very time constraining. Many facilities within the region get several hundred stranded animals a year; it would be a huge additional time commitment to those facilities to report each of the scenarios listed above, particularly human interaction cases, within 24 hours. A larger time interval for this information should be taken into consideration as well as the importance of this information (does NMFS need to know about every human interaction case when that information will be submitted through the National Database via the Level A form?). This information will be entered in Level A data forms and other stranding/necropsy data sheets, so the need to also separately report this information seems to be double duty for the responder(s). 

Many stranding network members alreahours of these events, since they may prequire assistance from the stranding covigilance in neighboring stranding respoprovide a 24 hour hotline to facilitate rapthat are unable to provide notice within interactions, unusual mortalities, potentstandings, out of habitat situations, masand listed species strandings occur shoStranding Coordinator to establish a muprogram and periodically update the list 

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Comments on the Stranding Agreement Template

13 Page 9

Article III, 

section B, part 

2 d

To require additional information, expedited reports (written and or verbal) of Level B and C data such as analytical results and necropsy reports within 24 hours is also another time restrictive issue. It is not feasible to ask organizations to turn over completed reports and analytical data within 24 hours of the stranding(s). The need to have this information within 24 hours of a stranding is a concern especially for smaller organizations that have limited staff and resources or for organizations that are inclined to have several animals strand simultaneously including mass strandings. It often takes weeks, if not months, to get analytical results, therefore a 24 hour frame is impractical.

Generally, the NMFS Regional Strandininformation over telephone calls, and thdiscussed and coordinated with the straphrase "as available" has been inserted for information that is available within 24 

14 Page 10

Article III, 

section B, part 

2 e

In regards to bullet point (e.), forms or instructions should be provided by the NMFS office. 

Network members who have not been tprocedures will be instructed by NMFS Coordinators or NMFS Office of Law Enprocedures to follow and forms to comp

13

Article III, 

section B, part 

3 a

The retention or transfer of any parts of marine mammals is filled out under the “Specimen Disposition” section on the Level A data sheet. It is redundant to also have to report this information to the NMFS Regional Stranding Coordinator within 30 days of the stranding(s) 

Currently, parts retained from stranded sometimes transferred well after a stranregulations implementing the MMPA reqRegional Administrator within 30 days oHowever, if the transfer occurs immediaA data report form submitted within 30 dadditional reporting is required. Proposare being considered (for possible publithe language regarding the transfer of sparts.

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Comments on the Stranding Agreement Template

20 Article III, section B and C

The language in the NOAA deliverables section is quite different from the language used in the Stranding Agreement Participant section. The NOAA deliverables section includes the phrase “as needed and as available,” while in the Participant deliverables section the wording changes dramatically to the participant “shall bear all expenses.” While it is appropriate to clarify the financial liability, we believe NOAA should cover the cost, if one exists, of all Level B or C data they request. Alternatively, the language could be changed to closely match the NOAA section; for example: “as needed and as funds are available”. 

NMFS and Participant Responsibilities aand D in the revised version. To ensure stranding network are clearly identified implement Title IV and other provisions stranding network activities are adequatStranding Agreement, the section on joiSection D. in original) has been moved the sections on NMFS and the network Additionally, the language in the particpbeen slightly modified to say Level B an"as resources are available" (Article III Supon request within 24 hours "if availabMany stranding agreement participants this information to NMFS within 24 hourparticularly strandings with severe signs activity, or emergent diseases. Additionally, Prescott funds have been mdata collection abilities of stranding orgapurposes of the MMPA. However, this cause participants to incur costs that thenormal course of their response. 

14 Page 11, 13, 16 Article IV, section A, part 1 b In regards to bullet point (b.), it is recommended that AVID chips and satellite tags be added to this list. 

AVID chips and satellite tags were not ain the NMFS Policies and Best PracticeNMFS Regional Administrator must recapprove the application of alternative m

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Comments on the Stranding Agreement Template

9 Page 16

Article V, 

section A, part 

1

Transferring an animal for "permanent disposition at an authorized facility" does not meet the purpose of this paragraph, which was stated to relate to "rehabiliation and release." Permanent display is not release as we understand the concept of release (and the term is not defined in the glossary) which implies release back to the wild. We are also concerned that this language in a section on the appropriate disposition of stranded animals may encourage animals to be taken from the beach for display rather than releasing them to the wild, particularly if they are from a specie sthat is novel or otherwise desirable to a captive display facility. Clause "c" should be omitted from the section dealing with "release" and the possibility of keeping stranded animals for permanent display should be considered elsewhere. 

The title of this section has been revised Rehabilitation and Final Disposition," reDisposition." NMFS regulations implemprovision to require the use of a rehabilitaken from the wild for public display (50 

20 Page 18

Article V, 

section B, part 

1 f

Article V, section B1, part f states that the stranding participants “shall prohibit the public display and training for the performance of stranded rehabilitating marine mammals as required by 50 CFR 216.27 (c) (5). This includes any aspect of a program involving interaction with the public.” We feel that the sentence, “This includes any aspect of a program involving interaction with the public” should be clarified and the terms defined. As it stands this would eliminate many highly effective yet non-detrimental education programs currently in progress. It would significantly impact many facilities that have free visitation programs to their rehabilitation centers.

Proposed changes to the regulations arpossible publication in 2008) to clarify/dundergoing rehabilitation. 

14 Page 18

Article V, 

section B, part 

1 f

In regards to bullet point (f.), we object to a blanket prohibition as public display is possible without impacting the rehabilitation of these animals. Language used in another document concerning distance viewing with no impact is preferred.

NMFS published an Advanced Notice o(January 31, 2008) to solicit comments to the regulations regarding public view

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Number Page/Line Section Comment NMFS Respo

Comments on the Stranding Agreement Template

14 Page 18

Article V, 

section B, part 

2 a

In regards to bullet point (a.), professional Husbandry staff is in a better position to assess the behavioral readiness and should either also sign or coordinate with the release determination paperwork.

As stated in the NMFS Policies and BesRelease, the release determination recosigned statement from the attending vetthe Assessment Team, stating that the and behaviorally suitable for release in criteria (i.e., similar to a health certificatplan and timeline. NMFS may also requfrom the “Authorized Representative” or Agreement. The Assessment Team caveterinarians, lead animal care superviswith knowledge of species behavior and 

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14 Entire document

Word choice sometimes implies requirements for "new" applicants only, but doesn't always specify. Please clarify differences between new and existing organizations throughout the document.

As stated in the NMFS Policies and BesCriteria for a Marine Mammal Stranding Athis document is for both renewals and nArticle is footnoted. To renew an existing the applicant must demonstrate past comand responsibilities of their Stranding Agreporting requirements and deadlines." Tclarified in the document.

4 Entire document

However, providing the scope and volume of information required in the General Evaluation Criteria for Stranding Agreement renewal will take many weeks of dedicated efforta task that many organizations that rely on volunteer services, including ours, may be unable to achieve in the foreseeable future. We urge NMFS to develop a simpler process, particularly for Stranding Agreement renewals. One possibility would be to reduce the written component and rely more on NMFS inspection teams to conduct onsite evaluations. 

NMFS intends to request a comprehensitypes of documents as part of the initial rand once for exisitng stranding participanreviews, organizations will only have to pdocuments. Most exisiting organizations of documents that can easily be shared w

20 Page 2-1 Section 2.1

This section states that a prospective SA must apprentice under a SA holder for a minimum of three years. We suggest that NOAA assign a number of rehabilitation cases to meet the minimum requirements rather then length of time.

Text revised to state "9. For prospective experience working under the direct supeStranding Network Participant in good stleast three years or equivalent case load

14 Page 2-1 Section 2.1, number 2

Organizations will need time to develop the documentation described in 2.1.2. It would be best if the agency would provide examples or templates to work off of. Alternatively, could the organizational summary used for Prescott Grant applications suffice? Perhaps the requirements for both this document and the organizational summary fo rthe Prescott grant application be unified. 

Much of the information requested for apGrant Program can also be used to fulfill for a new or renewal of stranding agreemmore information that is required includin

14 Page 2-1 Section 2.1, number 3

Bullet (a.) should read: Brief summary of the existing or proposed scope of the stranding program (e.g., all species of cetaceans, pinnipeds), and whether the request is for response to dead animals only, live and dead animals, and/or rehabilitation.

Text revised per comment.

Comments on the Stranding Agreement Criteria

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Number Page/Line Section Comment NMFS Respons

Comments on the Stranding Agreement Criteria

14 Page 2-1 Section 2.1, number 3

Bullet (b.) should read: Justification and description of the existing or proposed geographic area of coverage and why the area of response is appropriate for the organization (e.g., the amount of personnel/volunteers and resources available, relative to shoreline covered. 

Text revised per comment.

14 Page 2-2 Section 2.1, number 5

It would be helpful if NMFS could generate a complete list of items and the level of detail ("102 1" x 19G needles" or "a supply of various sized needles" or even just misc. sampling supplies) they are interested in. Otherwise, organizations may not cover what the agency is looking for. Again, an example or template would help. 

NMFS suggests referring to existing lliterof equipment, such as Marine Mammals Handbook of Marine Mammal Medicine, Oceanographic Institution's Necropsy Te

14 Page 2-3 Section 2.1, number 8 In regards to number 8, resumes are also required under 2.1.4b. Pick one place to cover this requirement.

Text for 2.1.4b. revised to state: "Brief sutraining, experience, and qualifications fopersonnel, including primary respondersvolunteers as appropriate."

14 Page 2-3 Section 2.1, number 9 In regards to number 9, this should apply to new Stranding Agreements only. This requirement is for new applicants on

clarified. 

14 Page 2-3 Section 2.2

The first paragraph should read: NMFS will evaluate existing and prospective participants based on their demonstrated track record and their capabilities in the following areas as described in their request. 

Text revised per comment.

14 Page 3-1 Section 3.1, number 1 In regards to number 1, what is the difference between representative and responder?

The following roles were clarified: The Au

is the individual with signatory authority forganization. This individual may be the agreement (e.g., Executive Director, PrePrimary Responder is who will be on-sitdead or live animals are being examined responsible for the day to day operations staff).

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Number Page/Line Section Comment NMFS Respons

Comments on the Stranding Agreement Criteria

13 Page 3-1 Section 3.1

Is NMFS going to provide required equipment lists that outline what they feel is necessary to collect Level A data? It is a concern that facilities may be penalized for not meeting the required equipment list. Throughout the NER facilities and organizations differ in size, number of staff and geographic area as well as in the quantity and variety of species of animals that strand. As a result the equipment needed to respond to strandings in one area may differ from another. 

NMFS suggests referring to existing literaequipment, such as Marine Mammals Asof Marine Mammal Medicine, and the WoInstitution's Necropsy Techniques for Biothe equipment list is for NMFS to obtain equipment caches that could be utilized response. 

20 Page 3-1 Section 3.2

Section 3.2 states that key personnel are required to have necropsy experience, but this seems unnecessary if level B and C data is only collected “if possible” as is stated in this section. If necropsies are not required, why is necropsy experience for staff?

NMFS believes that conducting necropsiimportant, but it may not always be posslogisitcs prevent retrieval of a carcass. It personnel know how to conduct some levsampling. 

20 Page 4-1 Section 4.2, section f

Although it states that this qualification is “preferred but not required” it should be removed since mass strandings are limited to only a few geographical locations throughout the nation.

Mass strandings have been reported in eUnited States. Mass strandings could be excluding cow-calf pairs. 

14 Page 4-2 Section 4.2, number 3 There paragraph should read: The prospective Participant should demonstrate knowledge of national, state, and local laws relating to live animal response. Text revised per comment. 14 Page 5-1 Section 5.1, number 1

Bullet (a.), Sub-bullet (iii.). The maximum holding capacity depends upon the species. For facilities that receive a number of different species and have flexible holding options, how would the agency determine max capacity? For example, a facility might have a pool that can hold several small animals (i.e. harbor seals) but only a couple large animals (i.e. Steller sea lions). Also, some organizations are limited more by staff and not space, now will NMFs take this into account?

Maximum capacity is determined prior to communicated to NMFS. As stated in the Agreement Template, the Participant shamaximum holding capacity for cetaceans the minimum standard space requiremenhoused in each holding area, and the avapersonnel as described in the NMFS PolStandards for Rehabilitation Facilities. A NMFS Regional Administrator is required exceeding the maximum holding capacityfor determining maximum holding capaciveterinary care, adequate volunteer suppadequate food and medical supplies, meadequate isolation capability, adequate waccess, and the ability to maintain currenrecords. 

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Number Page/Line Section Comment NMFS Respons

Comments on the Stranding Agreement Criteria

14 Page 5-1 Section 5.1, number 1 Bullet (b.), Sub-bullet (ii.). The sentence should read: Human health and safety throughout the rehabilitation facility. Text revised per comment.20 Page 5-3 Section 5.2, section 1 c “Experience in a supervisory role” should be defined. Does this mean supervising volunteers and interns during husbandry care or supervising the rehabilitation case?

The Animal Care Supervisor is responsprescribed treatments, maintaining hospcontrolling drug supplies. The person shtrained to deal with emergencies until the able to direct the restraint of the animalsadministration of post-surgical care, and appropriate medical records. It is importsupervisor should communicate frequentattending veterinarian to ensure that theraccurate information about medical issueshould be a licensed veterinary techniciatechnician who reports to, or is responsibveterinarian.

14 Page 6-1 Section 6 What is the policy for when the agency is proposing a designee for an existing organization?

As stated in the National Stranding AgreeStranding Agreement Holder (Participantorganization or institution to act on behalup to the Participant to agree to this arrarequest can come from the Participant or agreement must be mutual.

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Number Page/Line Section Comment NMFS 

15 N/A N/A

Specify actions that the Service plans to take to ensure that rehabiliation facilities are in compliance with the Interim Standards for Rehabilitation Facilities.

NMFS will send a qualified idocument existing facilities, areas of weakness. Once thinspections will be carried oensure complliance. 

21 N/A Entire document

I feel that the guidelines outlined in this document are acceptable as long as they remain guidelines and do not become regulations. The major issues I have are the discrepancies between the minimum and recommended standards. I do not understand how they relate and how they would be weighted if they became regulations. I feel most facilities will aspire to meet the minimum standards and improve their facilities. However, if the recommended guidelines become regulations this would require an additional upgrade coupled with an increase the cost of conducting rehabilitation. These upgrades would require and additional source of funding not able to be covered under the current John H. Prescott Rescue Assistance Grant Program. Currently the only way to fund moderate upgrades is through this grant program. Unfortunately if these funds are diverted from general operational support our programs will not be able to meet our obligations operationally. As the cap for funding is $100,000 (and we currently do not have enough funding to support the existing program proposals) when the b

Minimal Standards will be eStandards will not be enforcbecome regulations, but will guidelines to try to achieve uother forms of funding. Recused as a means of obtainin

Comments on the Rehabilitation Facility Standards

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Number Page/Line Section Comment NMFS 

Comments on the Rehabilitation Facility Standards

9 N/A Entire document

It would seem important to consider providing regulations with additional minimal facility standards, personnel qualifications, staffing patterns, and other aspects of facility-based rehabilitation to assure that animals are properly cared for and that the care is uniform nationally and not variable depending on where the animal has the misfortune to strand. Regulations also faciliate enforcement of standards of care. 

Acknowledged

21 N/A Entire document

Another general comment is that all references to tank diameters and dimensions should be based on actual animal size being rehabilitated in that tank and not the average adult length.

The standards ARE based omay reflect the largest anim

21 N/A Entire document

These changes assume that animals will not be in the facilities during construction and operations will be conducted offsite. Another problem associated with these upgrades is related to the continuous operations of the rescue program. If facility upgrades cannot be timed to coincide with a decrease in the number of animals, alternate housing would need to be secured. It would be helpful to have NMFS facilitate a coordinated plan, based on their need assessment throughout each region, to upgrade facilities so as not to create a response void.

Facilities should have approfacility into compliance. Vercapacity year-around. The iwhen it is optimal for each fawork between facilities woulmandated upgrade schedule

20 Page 1-2 Section 1.1

In the paragraph on unweaned neonate cetaceans, if the rehabilitation facility is considering permanent care, they should also provide an updated staffing plan to NOAA since an unweaned cetacean would likely require 24-hour care for weeks or months.

Any rehabilitation facility concetaceans must submit a placare information to NMFS arequires rehabilitation. Text response to comment below

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Number Page/Line Section Comment NMFS 

Comments on the Rehabilitation Facility Standards

21 Page 1-2 Section 1.1

The statement "prior to receiving an unweaned cetacean calf for rehabilitation, facility personnel must submit a plan to the NMFS regional coordinator which will include options and timeline for decisions regarding disposition" should be clarified whether that means receiving from another facility or picking it up from the beach, as most assessment would be done upon arrival at the facility. It should be modified to "shortly after receiving an unweaned cetacean calf for rehabilitation, facility personnel must submit a plan to the NMFS regional coordinator which will include options and a timeline for decisions regarding disposition."

Text clarified per comment. thoughtfully consider these toverall facility goals and objrehabilitate neonatal and/or to discuss and seek concurrdisposition since most of theThese issues need to be resapproved prior to admitting a

21 Page 1-3 Section 1.1.1

The statement “pools shall have a minimum horizontal dimension of 9.75 meters (32 feet) or two times the average adult length of the largest species in the pool, whichever is greater” should be changed to “pools shall have a minimum horizontal dimension of 9.14 meters (30 feet) or two times the actual length of the largest species in the pool, whichever is greater”

Text revised per comment.

15 Page 1-4 and 2-4 Section 1.1.3 and 2.1.3

Pages 1-4 and 2-4 state that shade structures or shelters must be provided when local climatic conditions could otherwise compromise the health of the animal. This standard is subjective and allows for broad interpretation. The Service should better define the conditions under which shade must be provided to animals that are undergoing rehabilitation, recognizing that, if such animals are unable to thermoregulate or swim and dive normally, protection from the sun is essential.

Text clarified per comment: must be provided to animals could compromise the healtcetaceans undergoing rehabdive, or thermoregulate, thuelements or shade." 

21 Page 1-5 Section 1.1.4

The statement “control air temperature above the pool between 50 – 80°F when appropriate to facilitate recovery” should refer to the environmental parameters encountered by the species undergoing rehabilitation.

It is beyond the scope of the every species. The phrase appropriate interpretation.

21 Page 1-12 Section 1.3.2

The statement “maintain records for tests with time, level and results – reviewed and signed monthly by the attending veterinarian” should add “or a husbandry care specialist”

Text clarified per comment: time, level and results – reviattending veterinarian or the 

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Commenter 

Number Page/Line Section Comment NMFS 

Comments on the Rehabilitation Facility Standards

20 Page 1-20 Section 1.6.1

Bullet three states, “Diets reviewed by a nutritionist and the attending veterinarian.” This request seems excessive. Most facilities do not have a nutritionist on staff, even the large facilities like the New England Aquarium. It should be enough that the attending veterinarian and the biologists evaluate and calculate the diets. Requiring that a nutritionist review all the diets may prove to be prohibitively costly for the majority of the rehabilitation centers when the husbandry and veterinary staff can manage this.

Text clarified per comment: attending veterinarian, or the 

21 Page 1-20 Section 1.6.1

The statement “diets reviewed by a nutritionist and the attending veterinarian” should be altered to “diets reviewed by a nutritionist, attending veterinarian or animal care specialist”

Text clarified per comment: attending veterinarian, or the 

20 Page 1-22 Section 1.6.6

Feed Records, Minimum Standard bullet three states that a girth measurement must be obtained weekly on cetacean rehabilitation candidates. While this may be okay in the beginning stages of rehabilitation, weekly captures in later stages are excessive. Every other week would be more appropriate with cetaceans in the later stages of rehabilitation.

Bullet 4 text revised to statemeasurements at least weeanimals. Girth measuremenaxilla and the anterior insertmeasurements are generally weighing the animal." Bullemeasurements or body weigpractical in the later stages oundue stress to the animal."

20 Page 1-23 Section 1.7.1

Veterinary Experience states that veterinarians be available to assess animals during mass stranding events. This should be clarified. In many smaller events veterinarians are often not on site but consulting via phone. We acknowledge that in some regions Participants often act on their own accord with limited or in the absence of veterinary oversight. Wording needs to provide direct guidance for these groups but should also not cripple more responsible mass stranding responders who work consistently under the direction of veterinarians. 

Text changed per commentavailable to assess animals or indirectly through trained 

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Commenter 

Number Page/Line Section Comment NMFS 

Comments on the Rehabilitation Facility Standards

20 Page 1-24 Section 1.7.1

Under Recommended for that section is states the vet be a full time employee or contracted veterinarian of record at facilities managing ten or more cetacean cases per year. This does not clarify if that included live and dead animals or just live? If the latter then this requirement could prove prohibitive for smaller facilities with traditionally low cetacean numbers.

A veterinarian experienced iavailable to consult on cetacregularly rehabilitate cetaceRecommended and not requfull time employees or contrcetacean medicine at faciliticetacean cases per year."

20 Page 1-24 Section 1.7.2

Minimum Standards. This section taxes the veterinarians with a lot of paperwork that seems excessive, particularly bullet two, which requires a review of Standard Operating Procedures every six months. One time per year is sufficient. Smaller facilities or those not associated with a larger park or Zoo have contracted veterinarians who have another full time job in private practice. While we strongly support veterinary oversight we also think the demands on the veterinarian’s time should be reasonable and focused on animal health and direct animal care. Non-veterinarians can perform some of the tasks listed here.

Bullet 2 text revised to stateshould be reviewed and initior the animal care supervisodocument is changed or updreviewed by NMFS as part oor as part of inspections." 

20 Page 1-28 Section 1.9.1

Bullet 13 states that medical records should be available for NMFS review upon request. It should be clarified that this statement does not mean that NMFS is able to retain copies of the medical files or diagnostic results, because these are level B and C data and are owned by the Participant. This should be modeled after the AFIS [APHIS] regulations where regular inspections and reviews take place but AFIS [APHIS] does not retain copies. An agent visits the facility and reviews the documents in house. Bullet 14 states that medical records must be kept on site for a minimum of 15 years. It should be clarified if this means hard copies or computer copies. Computer copies can be kept more easily, whereas hard copy storage may be problematic. If this refers to hard copies then ten years on site or fifteen years at a secured storage area should be sufficient. (This is restated in the Pinniped section).

Medical records should be astatement is straightforward Medical records may be kepretrieved.

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Commenter 

Number Page/Line Section Comment NMFS 

Comments on the Rehabilitation Facility Standards

20 Page 1-31 Section 1.14

Training and Deconditioning Behaviors states the staff veterinarian should evaluate the benefits of training. We recommend that a person with at least three years of operant conditioning with cetaceans be consulted regarding the training plan and the plan for deconditioning. Phone consult would be sufficient before, during and prior to the deconditioning. Many marine mammal trainers will provide support free of charge.

Text clarified per comment: with humans, including trainmedical case by providing menrichment, and may facilitarelative costs and benefits othe attending veterinarian athe likelihood of contact with be considered. Seeking advbehaviorist (with at least 3 ybeneficial." 

23 N/A Section 2

Throughout this document, suggest that "at the discretion of the attending veterinarian" be applied to many if not all of the minimum standards. Many situations arise during medical treatment and rehabilitation of stranded marine mammals where it might actually be detrimental to their recovery to follow the standards. For example, activity and access to water may need to be severely limited for animals with fractures. 

This is why most standards at the discretion of the atten

14 Page 2-1 Section 2.1

Paragraph 4. The last sentence reads: Pinnipeds with evidence of infectious disease must be quarantined (See Section 2.4 Quarantine). Does this mean that Pinnipeds with infectious diseases should be quarantined from other rehabilitating animals? How many isolation areas are expected?

Pinnipeds with evidence of iin separate areas from otheprevent transmission of diseprepared to isolate incoming away from other animals utiand water-bourne exposurewith evidence of infectious dareas from other rehabilitatintransmission of disease. Theareas to accommodate incodisease utilizing methods to exposure to other on-site anQuarantine)."

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Commenter 

Number Page/Line Section Comment NMFS 

Comments on the Rehabilitation Facility Standards

23 Page 2-1 Section 2.1

Due to variations amongst the most commonly rehabilitated species, their growth rates, and varying sizes at different life stages and age classes, standards for space requirements should be based on the individual animal housed at any given time, and not generalized on measurements of adults of the same species. 

We recommend that such infacility SOPs using this docu

18 Page 2-2 Section 2.1.1

In Section 2.1.1 the recommended standard for pools is for them to meet USDA, APHIS regulations. These standards are based on the adult length of the largest species housed in that pool and were developed for permanent display facilities. These standards would not be very practical for rehabilitation facilities like our who handle primarily pups and juveniles of various species that can grow to be quite large and rarely, if ever, strand in our area of response as adults. Also, it is not very clear whether these strandards would apply to all pool used for rehabilitation or only those used for holding animals in the final stage of care prior to their release. 

Recommended Text revised area of the pool for non-critito the dry resting area requistandards, but using the actthe enclosure instead of the 

21 Page 2-2 Section 2.1.1

The statement “facilities where numerous pinnipeds are rehabilitated consistently each year should be equipped with at last one pool and haul-out area that meets APHIS standards for at least one adult of that species where one or more per year strands as adults” should be altered to “facilities where numerous pinnipeds are rehabilitated consistently each year should be equipped with at last one pool and haul-out area that meets APHIS standards for at least one adult of the species when the average of occurrence increases to one or more per year.

Recommended Text revised are commonly rehabilitated, accommodate the average nstrand each year, and have area that meet USDA APHI

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Commenter 

Number Page/Line Section Comment NMFS 

Comments on the Rehabilitation Facility Standards

23 not sure (p2-12?)

Suggest that the temperature range of 60-80F is too narrow and unrealistic. The range should be the same as pinniped species are exposed to in the wild, with protection from extremes of heat and cold. 

Text clarified per comment: temperature, as appropriate temperature should be availconstant water sprays and fhave no access to pools durtemperature exceeds 85°F (devices or waterproof heatinambient temperatures fall beanimal, which will be determcondition, and body conditioAnimals should be able to mheaters. If animals are too dof heaters can not exceed thsurface or animals must be 

23 Page 2-2 to 2-3 Sections 2.1.1 and 2.1.2

As stated in 9CFR3.110 (revised January 1, 2005), Sec 3.110(b): "Holding facilities used only for medical treatment and medical training need not meet the minimum space requirements as outlined in Sec 3.104. Holding of a marine mammal in a medical treatment or medical training enclosure that does not meet minimum space requirements for periods longer than 2 weeks must be noted in the animal's medical record and the attending veterinarian must provide justification in the animal's medical record. If holding in such enclosures for medical treatment and/or medical training is to last longer than 2 weeks, such extension must be justified in writing by the attending veterinarian on a weekly basis." Since the USDA-APHIS standards make a specific exception for medical treatment, and since rehabilitation facilities are by definition providing medical treatment, there should be no requirement for rehabilitation facilities to meet the same USDA-APHIS standards for marine mammal housing for longterm/display facilities. The exception for medical treatment should remain.

Not all animals in rehab requoversees marine mammal reno mandate that these facilitas they were developed for certain circumstances, we restandards as applicable. 

Page 45
Commenter 

Number Page/Line Section Comment NMFS 

Comments on the Rehabilitation Facility Standards

23 Page 2-2 to 2-3 Sections 2.1.1 and 2.1.2

To reduce paperwork, particularly in high-volume rehabilitation centers, we suggest that an exception be made to the required weekly written justification for holding animals under medical treatment. Holding in appropriate facilities for medical care should be permitted until the rehabilitated animals are deemed healthy for release by the attending veterinarian. 

NMFS does not require weeimplement the MMPA for NM216.27(a)(1)) require that a rehabilitation be released wiattending veterinarian determmammal might adversely aff(ii) Release of the marine msuccessful given the physicamarine mammal; or (iii) Morwhether the release of the mlikely be successful...” and (shall provide the Regional Dwritten report setting forth th

23 Page 2-2 to 2-3 Sections 2.1.1 and 2.1.2

Veterinary discretion should apply to all pool dimensions, not just surface area of the pool, as written in the recommended standards.

Section 2.1.1, minimum stanstate: "Critically ill animals oappropriately, with the pool resting area determined by tveterinarian." Section 2.1.2, revised to state: "Animals msmaller areas at the discretiattending veterinarian shoulwhich will be most appropriacondition of the animal."

23 Page 2-3 Section 2.1.2

The description of how to calculate dry resting area is confusing to read. We suggest that a table be prepared, based on body length, for the required surface area. This table could be similar to the one for cetaceans in 9CFR3.104, which is based on body length and not on species. 

Species specific tables are bdocument. Each facility may on the sizes and species mo

14 Page 2-3 Section 2.1.2 3rd bullet point. Sentence should read: The facility must have a plan to manage adult males. Text revised per comment.

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Commenter 

Number Page/Line Section Comment NMFS 

Comments on the Rehabilitation Facility Standards

14 Page 2-4 Section 2.1.5

Paragraph should read: Animals housed at rehabilitation facilities must be provided with shelter to provide refuge from extreme heat or cold. Pinnipeds held in rehabilitation facilities may not have normal activitiy levels and thin animals may be unable to thermoregulate properly. These animals may require shade structures to protect them from direct sunlight and extreme heat, or shelter to protect them from cold temperatures or inclement weather. Animals held in indoor facilities should be provided with appropriate light and dark photoperiods which mimic actual seasonal conditions. Except during pre-release conditioning phase, ensure adequate refuge from extremes. 

Text revised to state: "Animafacilities must be provided wextreme heat or cold...At the veterinarian an exception to the pre-release conditioning should be protected at all ti

23 Page 2-4 Section 2.1.6

Please clarify whether the proposed minimum standard applies to indoor facilities only. For outdoor rehabilitation facilities, there is no practical way to control ambient air temperature. 

Outdoor enclosures may emfans, etc. to help control am

23 Page 2-4 Section 2.1.6

Suggest that if protection from extremes of heat and cold are provided, such as access to heating pads, shelters, shade, water spray, etc., the holding of animals in such areas should be at the discretion of the attending veterinarian. 

Acknowledged

23 Page 2-5 Section 2.1.7

The language in section [2.]1.7 is more generally appropriate for ambient conditions: provide shelter from extremes of heat or cold, and provide heat as appropriate for animals held in cold climates.

Acknowledged

23 Page 2-5 Section 2.1.7 Please clarify what "appropriate in size" means for individual dry haul out space or individual enclosures. 

Text revised to state:"Individindividual enclosures shall bthe most common species oat the facility."

23 Page 2-5 Section 2.1.7

Providing a structurally separate quarantine facility for all incoming animals in not necessarily appropriate or feasible. If there is adequate separation between portions of a structure and between animals, that should suffice.

Text clarified per comment: incoming animals until the athem to be free from contagQuarantine)."

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Commenter 

Number Page/Line Section Comment NMFS 

Comments on the Rehabilitation Facility Standards

14 Page 2-5 Section 2.1.7

4th bullet point. Is the structure referenced in the paragraph meant ot be a separate building? Or can it be separate rooms/holding areas that prevent exchange of water and bodily fluids as well as prevent 'nose-to-nose' contact with other animals? This requirement is stricter than the requirement listed on page 2-15.

Text revised to state: "Barrieanimals until the attending vfree from contagious diseas

23 Page 2-6 Section 2.1.8

Housing arrangements should be at the discretion of the attending veterinarian and/or trained husbandry staff. In many situations, paired or group housing of young animals helps to decrease stress.

Text revised to state: "Accesresting areas for pups of all veterinarian."

23 Page 2-6 Section 2.1.8

Raised platforms (in both section [2.]1.8 and [2.]1.9) are not appropriate, as animals in the wild often haul out and sleep on hard, cold surfaces. Dry resting areas may be appropriate and necessary for critically ill animals, but should be at the discretion of the attending veterinarian. 

Text revised to state: "Criticabe required to lay on concre

14 Page 2-7 Section 2.1.10

1st bullet point. Addition of the following sentence: Dependent pups are more labor intensive and require more staffing. 

Text revised per comment.

23 Page 2-8 Section 2.1.11

Requiring enrichment items to be non-porous and cleanable excludes most if not all natural items, such as kelp, driftwood, etc. Suggest that if items are not porous and easily cleaned, that they be disposable and not shared between pens or pools, e.g. used for only one animal or group of animals. 

Generally speaking, driftwoorehabilitation situations. The exactly but to provide approand cleanable or disposable

23 Page 2-8 Section 2.1.12

Preventing contact between rehabilitating animals and all wild animals (i.e. birds, small rodents, insects) is not feasible, particularly for outdoor facilities. Control is appropriate. 

Contact is prevented by pesrevised to state: "This shoulto prevent feral and/or wild arehabilitating animals."

14 Page 2-10 Section 2.2.1

2nd bullet point. Sentence should read: Drain water from pools as often as necessary to keep the pool water quality within acceptable limits. 

Text revised per comment.

14 Page 2-12 Section 2.3.2

1st bullet point. Sentence reads: Measure water temperature, pH, salinity (if applicable), chemical additives (if applicable) daily in all pools. Does this apply to open flow through systems with natural sea water?

Yes, this applies to open flow water temperature.

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Commenter 

Number Page/Line Section Comment NMFS 

Comments on the Rehabilitation Facility Standards

23 Page 2-14 Section 2.3.7

Holding water temperature within the normal habitat range is not feasible, nor is it necessary for short-term rehabilitation. Suggest that this be changed to "protect from extremes of heat and cold," as in other sections. 

It is reasonable to hold watehabitat range, which is genetemperature which exceeds extreme of heat or cold. 

23 Page 2-15 Section 2.4.1

Individual quarantine of all animals is not necessary or appropriate. Please insert language indicating that batch quarantine is permitted and appropriate, as animals are often admitted in groups during seasons.

Text added to bullet 1 to stagroups may be quarantined 

23 Page 2-15 Section 2.4.1

Eye shields or safety glasses are not necessary or appropriate. Suggest changing this to the provision of eyewash stations, and the option for personnel to wear shields or glasses at their discretion.

Text revised per comment.

14 Page 2-15 Section 2.4.1

In regards to the 1st bullet point, the use of dividers, tarps, or physical space is very different from the structurally separate facility referenced on page 2-5. The description listed here is much more reasonable. 

Text on page 2-5 has been here. Revised text states: "incoming animals until the athem to be free from contagQuarantine)."

14 Page 2-15 Section 2.4.1

In regards to the 5th bullet point, the sentence should read: Maintain equipment and tools strictly dedicated to the quarantine areas or thorough disinfection.

Text revised per comment.

23 Page 2-16 Section 2.4.3

It is not practical to build perimeter fencing that will prevent all wildlife from entering the premises. Suggest deter instead of prevent. 

 Text clarified per comment: deter wildlife from entering t

23 Page 2-16 Section 2.4.3

Similarly, it is not practical or even desirable to build net pens that will keep all wildlife (i.e. fish) from coming into contact with rehab animals. 

Bullet 3 text revised to stateareas have sufficient secondmammals from coming in dihoused in the net pens."

23 Page 2-17 Section 2.4.6 Placing a second set of perimeter nets 30 feet from the pens is not practical nor always desirable. It is desirable to provide a b

and other wild mammals an

23 Page 2-17 Section 2.4.6

We suggest that placing pens 1000 m from storm drains is not practical (i.e. run-off from building roofs, etc., can be considered storm drains). Limit this requirement to sewage outfall. 

Text revised per comment.

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Commenter 

Number Page/Line Section Comment NMFS 

Comments on the Rehabilitation Facility Standards

23 Page 2-18 Section 2.4.6

Daily coliform testing for net pens is not practical. Pens may be located in remote areas where testing cannot be carried out, and it is also not feasible to control the coliform count in open water areas. 

It is necessary to have some pens, even if weekly. Water move water if coliforms tend to state: "Weekly coliform tebuild-up exists. Water circuwater paddles."

23 Page 2-18 Section 2.4.7

Obtaining full bloodwork, cultures, etc., is neither practical nor appropriate in all cases. For example, diseases such as leptospirosis, which is endemic in certain wild populations, can be presumed present in certain groups of animals, and they can be housed together appropriately without extensive preliminary testing. 

Text Clarified per comment: cultures, physical examinatiquarantine area and at the dveterinarian."

23 Page 2-18 Section 2.4.7

Please clarify the meaning of contingency plan. Is this a treatment plan for the various conditions listed? Housing plan? Please also clarify which diseases are reportable for marine mammals, and to which agency. CDC? WHO? OIE? USDA? Suggest that a table would be helpful. 

A contingency plan should boutbreak of highly infectious facility - the need to separatrelease from those with highshould include housing planguidance regarding "reporta

23 Page 2-18 Section 2.4.8

This section is very vague. All pinniped handling may result in exposure to potentially zoonotic pathogens. So does all handling, including beach rescues, require full protective gear?

Bullet 5 text revised to stateequipment, as reasonable, sprotection and face masks tzoonotic diseases (see Occfor Marine Mammal Workers http://www.vetmed.ucdavis.e

23 Page 2-20 Section 2.6

Suggest check of wild pinniped foraging literature, as there are many reports that pinnipeds will forage and then haul out for several days. 

The biggest concern is with clariy this: "Feeding regimenweight gain for underweight should simulate natural pattquantity to the extent possibcourse of medical treatment

14 Page 2-21 Section 2.6.1 In regards to the 3rd bullet point, it is excessive for a public display aquarium to have a nutritionist on staff. A nutritionist need not be on 

text revised to state: " Diets attending veterinarian, or the 

Page 50
Commenter 

Number Page/Line Section Comment NMFS 

Comments on the Rehabilitation Facility Standards

23 Page 2-21 Section 2.6.2

If daily food intake is recorded per animal or per group, then kCals consumed can be calculated if/when necessary from the medical records. Requiring daily calculation is adding unnecessary work. 

Some facilities have worked computer programs. The carecommended standard, not 

23 Page 2-21 Section 2.6.2 Suggest that the composition of each diet routinely used be calculated. Text revised per comment.23 Page 2-21 Section 2.6.2

Fish supplies maintain composition analysis records for each batch. It is not necessary for each facility to replicate that work. 

Text added to bullet 2 to stamay be used and a copy sh

23 Page 2-22 Section 2.6.6

Daily feed records cannot be maintained for individuals when they are housed in groups. Group records can be maintained, and together with daily husbandry notes and weekly records of weight provide sufficient indication of individual animal consumption. 

Text added at bullet 2: "If angroup feed records shall be husbandry notes and weekly of sufficient feed intake." 

23 Page 2-22 Section 2.6.6 Please indicate that food can be weighed before and after feeding to individuals or groups. Text revised per comment.23 Page 2-23 Section 2.7.1

It is not possible for an attending veterinarian to certify that animals are likely to survive, or that they are free from known communicable diseases. We do not test for all known communicable diseases, so we cannot certify that animals are free from them. For example, E. coli is a potentially communicable pathogen, and all animals certainly have E.coli. Suggest that a more appropriate standard is that animals must be free from clinical signs of disease, able to swim and dive, and free feed. 

We agree and as mandated Marine Mammal Protection Aguidance and criteria for relechances for survival and minpopulations (NMFS/FWS BEMammal Stranding ResponsStandards for Release ). Thdeveloped to achieve the goRelease.

20 Page 2-23 Section 2.7.1

Section 2.7.1 in the Pinniped section also recommends that the vet consult with the vet on record at facilities managing over 50 pinniped cases per year. Does this included dead animals? If not this seems to go against NMFS new direction of making difficult decisions.

The 50 cases included both 

14 Page 2-23 Section 2.7.1

8th bullet point. Sentence reads: Have contingency plan for veterinary backup. This should be the responsibility of the facility and not the veterinarian who may be a volunteer. 

We agree and this point is aPractices for Marine MammRehabilitation, and Release Mammal Stranding Agreeme

23 Page 2-25 Section 2.7.2 Suggest that annual review of SOPs is sufficient. Text revised per comment.

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Commenter 

Number Page/Line Section Comment NMFS 

Comments on the Rehabilitation Facility Standards

23 Page 2-25 Section 2.7.2 Please clarify what constitutes a health and safety plan. Is a preventative health program required for all staff/personnel? 

A health and safety plan for accessible at all times. It shveterinarian or the animal caprescribed by the NMFS Strcare staff will be familiar with include protocols for manag

14 Page 2-25 Section 2.7.2

6th bullet point. It is not appropriate to assign human health plans to the veterinarian. A human health plan should be developed by the Human Resource personnel with the help of a human medical professional. This should be the responsibility of the facility, not the veterinarian. 

Often the veterinarian is the associated with a facility. Wbeneficial to consult with an professional when developin

14 Page 2-25 Section 2.7.2

The following reports should be the responsibility of the facility and not the veterinarian: Health and Safety Plan reviews; Animal acquisitions and dispositions; NOAA Form 89862, OMB#0648-0178 (Level A data); NOAA Form 89878, OMB#0648-0178 (Marine Mammal Rehabilitation Disposition Report).

In some instances the vet is should allow for other qualifiresponsibility inlcuding the aorganization stranding coord

23 Page 2-25 Section 2.8

Suggest that one blood sample and CBC/serum chemistry is sufficient, as admit and release exams may be the same in many cases. Additional testing should be at the discretion of the attending veterinarian. 

Text clairfied per comment: have a minimum of two bloodifferential and serum chemrelease (see NMFS/FWS BEMammal Stranding ResponsStandards for Release ). If shorter than a week, one blothe attending veterinarian's 

23 Page 2-25 Section 2.8

Measuring girth is not practical in all cases, for example when manual restraint of large animals is used for exams. Most formulas are based on length and weight, so standard length and weekly weights should be sufficient. Suggest that girth measurements be recommended but not required. 

Text revised per comment.

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Commenter 

Number Page/Line Section Comment NMFS 

Comments on the Rehabilitation Facility Standards

23 Page 2-26 Section 2.8 Suggest that complete necropsies performed within 72 hours are sufficient, and that 24 hours is not practical. 

Text clarified per comment: trained staff member shall panimal that dies within 24 honecropsy is to be performed than 72 hours postmortem), appropriately to delay tissue 

23 Page 2-26 Section 2.8

Suggest that histopathology on select tissues is at the discretion of the attending veterinarian, as for cultures and other diagnostic sampling. 

Text clarified per comment: will be issued by the NMFS Onsite Coordinator) in each Mammal Health and Strandideterminations, surveillance investigations. Routine diagprotocols will be determined 

23 Page 2-26 Section 2.8

Please clarify which disease are reportable for marine mammals (see notes above), and also which disease require notification to NMFS. 

NMFS, through the NMFS sfuture guidance regarding "rReportable Diseases as patconcern to public health, agpopulations and are required state agencies. 

23 Page 2-26 Section 2.8

Release should be at the discretion of the attending veterinarian. Advance notice to NMFS is not always practical nor in the best interest of the animal, e.g. animals very stressed by captivity. 

Text clarified per comment: adequate time and informatiof health) before the animal directed in 50 CFR 216.27 (Release). This information is 216.27(a) and must be submunless advanced notice is wAdministrator. Guidance on NMFS/FWS BEST PRACTICStranding Response, Rehabfor Release." This regulatory considered for cetacean cas

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Commenter 

Number Page/Line Section Comment NMFS 

Comments on the Rehabilitation Facility Standards

14 Page 2-26 Section 2.8

10th bullet point. Sentence reads: Serological assays may only go to labs that have validated tests approved by NMFS, especially for release decisions or determinations. What does validation constitute? What labs are these? Will NMFS keep up with validations?

Text clarified per comment: decisions, unusual mortality programs, serologic assays validated tests approved by decisions or determinationsNMFS Stranding Coordinato

23 Page 2-26 Section 2.8

For recommended standards, frequency of blood sampling beyond the single collection should be at the discretion of the attending veterinarian. 

For most cases, all animals blood samples drawn for CBchemistry; upon admission aNMFS/FWS BEST PRACTICStranding Response, Rehabfor Release ). If duration of week, one blood workup maveterinarian's discretion. Sbe issued by the NMFS straCoordinator) in each region Health and Stranding Respodeterminations, surveillance investigations. Routine diagprotocols will be determined 

23 Page 2-26 Section 2.8

Please explain the utility of banking the buffy coat. Suggest that it be performed on selected animals only subject to utility. 

Text revised per comment.

23 Page 2-28 Section 2.9.1

Under recommended record keeping: Please define the set of standard morphometric measurements that should be collected and include a suggested recording format.

There are several good resomammal morphometric data Field Guide for Strandings). other experts in the field and data collection protocols.

23 Page 2-28 Section 2.9.1

Under recommended record keeping: Suggest that obtaining photographic documentation of all animals is not practical and of questionable utility. Animals with distinguishing markings, or other unusual features could be documented. 

This is a "Recommended" sfacilities with a small to med

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Commenter 

Number Page/Line Section Comment NMFS 

Comments on the Rehabilitation Facility Standards

23 Page 2-28 Section 2.9.1

Under recommended record keeping: Please see the previous comments on determining the daily caloric intake for each animal. This is not practical and of questionable utility, particularly in high volume centers. If caloric value of commonly used diets is calculated, and then minimum intakes are set based on weight, that should be sufficient. Additional calculations should be at the discretion of the attending veterinarian.

This is a "Recommended" scapable of recording the calin their care, and it has provmeasure, and in some instarehabilitation efforts. 

23 Page 2-28 Section 2.9.1

Under recommended record keeping: Daily weighing of pups is too stressful and results in too much handling. Suggest that weekly weight be required, more frequently at the discretion of the attending veterinarian. 

This is a "Recommended" sunderweight pups is beneficmay be more difficult to weigat the discretion of the atten

23 Page 2-28 Section 2.9.2 Please define "real time accessible compiled comparative data." 

This is a "Recommended" scase data (Level B and C daeasily accessible if the need other words, organize files aand accessible manner so thother data sets. This is impobeing considered by the WoUnusual Mortality Events. 

14 Page 2-30 Section 2.13 The verbage in this paragraph differs from what is in the Stranding Agreement Template. This is a better version.

Text clarified per comment: CFR 216.2(c)(5) states that rehabilitation shall not be sudefinition of public display uthat provides opportunity for mammals at a facility holdinremote public viewing or disand only when there is no pviewing on the animals beinregulatory requirement for a facilities planning to offer pumammal undergoing rehabil

Page 55
Commenter 

Number Page/Line Section Comment NMFS R

15 N/A N/A

Discuss the criteria that the Service intends to use in its review and approval or disapproval of recommended releases of marine mammals, and plans for such releases, by rehabilitation facilities.

This document outlines the criterrecommended releases. For a lcovers cetaceans, section 4 is pisea otters is section 6, and polar decision tree that will be used to determination is Figure 2.1, page 

15 N/A N/A

The interim standards [for release] do not, however, recognize that, for some species, there may be a countervailing incentive to retain marine mammals for longterm maintenance in captivity and, perhaps, eventual placement at a public display facility. For such circumstances, protocols need to be established to ensure that the rehabilitation of animals and their preparation for eventual release to the wild are pursued diligently and with suitable agency oversight. 

The decision to maintain a releasauthorized scientific research or NMFS regulations (50 CFR, sectdoes not preclude this decision, bthe criteria by which this decision 

15 N/A N/A Identify the types of information that would be included in protocols for monitoring released animals.

Section 3.9 was edited to include monitoring plan should include, aidentification used (tag, brand, etmaking observations (both visual expected duration of the monitoriintervention; and how information disseminated to others who may individual animals, additional info

14 N/A N/A

NMFS & USFWS should take into account the recommendations of the stranding facility and the AZA Taxon Advisor or Studbook Keeper for the species before making a decision as to placement. 

NMFS has met with representativWe are finalizing the process by placements of animals at membeThis process will take into accounStudbook Keeper. Additionally, acoordinated with APHIS. ANPR stranding facility (not maintaining 

Comments on the Release Criteria

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Commenter 

Number Page/Line Section Comment NMFS R

Comments on the Release Criteria

9 Page ES-1 and Page 5-2 Executive Summary and Section 5.2

Page ES-1 says one of the categories is "conditionally nonreleasable (manatees only)." The definition of this term does not occur until page 5-22. Nowhere is it explained why this term applies only to manatees. It appears unnecessary or else this category should apply to other species as well...Why is this term not used for cetaceans and/or pinnipeds? Why only manatees? The DEIS should explain the unique circumstances that require this extra category here and in section 5.

The EIS does not include manateconditionally non-releasable catecetaceans or pinnipeds within the regulations, we presume that pinbeen held in rehabilitation for lonupon release to the wild due to thlearned conditioned behaviors duhumans. Text has been added to “Conditionally Non-releasable” is because the FWS has had succebeen in captivity in excess of 20 ydeemed “Non-releasable” if they years (see 50 CFR 216.27(a)(1)(Non-releasable” category is not n

24 Page 2-1 Section 2.1.1 ...NMFS Policies, last sentence, delete "with" [before "NMFS Regional.."] Text revised per comment.

9 Page 2-2 Section 2.2

Page 2-2 and others have a discussion regarding determinations of suitability for release of animals from rehabilitation facilities...This does not address the concern about facilities taking into rehabilitation animals with a very poor prognosis for release....As we noted above, the NMFS should provide clearer guidance. 

In the Final PEIS, Section 6 descworkshop to discuss and outline is a good rehabilitation candidiateguidance and training will be plan

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Commenter 

Number Page/Line Section Comment NMFS R

Comments on the Release Criteria

24 Page 2-3 Section 2.2

...a facility may also request permanent placement under Section 104(c)(3) if an ESA-listed marine mammal is determined unreleasable. Please edit the last paragraph on this page to reflect such: " For FWS species, LOA and permit holders provide recommendations to the FWS Field Offices for decisions regarding releasability of rehabilitated marine mammals (see Appendix H for contact information). The FWS retains the authority to make the final determination on the disposition of these animals. If FWS determines that a marine mammal is non-releasable, the holding facility may request a permit for permanent placement in captivity as prescribed in Section 104(c)(7) of the MMPA for non-depleted species, or Section 104(c)(3) of 104(c)(4) and Section 10(a)(1)(A) of the ESA for depleted species."

Text revised per comment.

9 Page 2-9 Section 2.4

Similar questions should be provided elsewhere to guide a determination of the suitability of an animal for transfer from the beach to a rehabilitation facility (versus either euthanasia or beach release). 

In the Final PEIS, Section 6 descworkshop to discuss and outline is a good rehabilitation candidiatedevelopment of similar questions

14 Page 2-9 Section 2.4, number 1

When taking an animals history, does mouthing qualify as a bite or does the word bite pertain to an animal breaking the skin of a human?

Revised text to read "attacked anunprotected skin) a human while Section 4.3, number 5 with same 

14 Page 2-12 Section 2.4, number 4

5th paragraph. The third sentence of this paragraph refers to microbial culture. Other than the obvious wounds, what would the 'routine' samples come from? Fecal? Nasal?

Routine samples for surveillance and could include fecal, wound, oRecommended sample collectionsections for each taxon. Questioroutine surveillance are asked in forthcoming following the receipt making by NMFS.

14 Page 2-13 Section 2.4, number 5 Bullet (a.). Satellite tags should be added to list of pre- approved identification systems. Satellite tags added to the list of 

However, please note that satelliapproved and require consultatio

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Commenter 

Number Page/Line Section Comment NMFS R

Comments on the Release Criteria

14 Page 2-13 Section 2.4, number 5

Bullet (a.). Sentence should read: Invasive procedures should be done under the direct supervision of the attending veterinarian and will need prior approval from NMFS and FWS and may require a monitoring period following the procedure.

Text revised per comment.

14 Page 2-14 Section 2.4, number 5

First preference is releasing the animal in the same general/geographical area where the animal was stranded. The second choice, especially if the animal was stranded outside of its normal range, it to release the animal closer to or within its normal range. This is implied later but should probably also be referenced here. 

This is addressed more specificataxon in later sections. Also, the animal should be only one considsite, as determination of an appromade using many factors, outline

20 Section 3.8

Marking for Individual Identification of Cetaceans prior to Release. This section suggests three forms of identification prior to release. One of these is non-invasive while the other two are invasive. We are concerned about freeze branding and whether this is really necessary with a dorsal or satellite tag in place?

Freeze branding is viewed as the of identification. Photo-identificatanimal, and photo-id catalogues only for certain species. Any extrip, or migrate out of the animal. valid identification methods in the possibly years), whereas freeze banimal (with some fading). This for clarity; we are recommending the dorsal fin and/or on the side obasis).

14 Page 4-4 Section 4.3

Section 4.3 beginning on page 4-4 is formatted differently than 4.4, 4.5, and 4.6, using the number subsections that more or less correspond to the checklist. 4.5's Behavioral subsections are given paragraph numbers. Recommend you standardize the style. 

Text revised per comment.

14 Page 4-4 Section 4.3

The organization for section 4.3 should mesh with the checklist presented later in the document. Each point on the checklist should be described here and each point here should have a corresponding question on the checklist. 

Checklist in Section 4.7 was re-oin Section 4.3.

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Commenter 

Number Page/Line Section Comment NMFS R

Comments on the Release Criteria

14 Page 4-5 Section 4.3, number 4

The last sentence should read: Consultation with NMFS or FWS is thus required for pinnipeds that have a known history of exposure to terrestrial animals. Note: You can never know for sure what happened before an animal was reported and brought in. 

Revised text to read "pinnipeds t(i.e., confirmed or suspected)."

14 Page 4-5 Section 4.3, number 5

In regards to the first sentence, you might want to more precisely define bite to specify breaking of skin. "Bites" may occur without a breach of protective gear. Also, when tubing an animal, "bites" may occur without breach of protective gear. 

Included mouthing of unprotected 

14 Page 4-5 Section 4.3, number 5 In regards to rabies among pinnipeds, there is only one documented case. 

Referenced publication; Howevecase has been published there aare likely other cases where the nperformed.

14 Page 4-5 Section 4.3, number 6 This sentence is confusing. Perhaps more detail can be added. Added text "as deemed by NOAA 

Department of Justice, or other F

14 Page 4-5 Section 4.3, number 7 We assume that just because an animal was at 2 places, does not mean it isn't releasable.

Correct, it does not mean that the However, it is important to obtain facilities in order to fully evaluate release determination.

14 Page 4-9 Section 4.6

2nd paragraph. In the first sentence, list desired parameters. What does Chem-12 include? Also in the first sentence, delete blow hole as a sampling site for pinnipeds. 

"Blow hole" changed to "nasal." (including BUN and creatinine, en

14 Page 4-9 Section 4.6

2nd paragraph. In the third sentence, 3ml of Serum is recommended but another document recommends 1ml per draw. Please clarify. 

Text standardized to read 3 mL, release.

14 Page 4-10 Section 4.7

Recommend structuring this checklist as a stand alone document for greater usability. Recommend keeping it <2 pages and reduce font size as needed.

The checklist has been added as Appendix J. 

14 Page 4-11 Section 4.7

New Point, History: The environmental conditions are considered acceptable (e.g. prey available, no lingering contamination). 

The considerations of a release senvironmental conditions) will anthe health certificate for the animsignature). The release site detethe documentation provided to N

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Commenter 

Number Page/Line Section Comment NMFS R

Comments on the Release Criteria

14 Page 4-11 Section 4.7 7. Please define "bite" somewhere.

As stated elsewhere in the documunprotected skin or breaking the added to the glossary.

14 Page 4-11 Section 4.7 17. Is this the release determination exam? Don't you have to submit release paperwork 2 weeks prior? Modified form to have columns fo

days in advance) and Pre-releasModified Section 4.6 to clarify

14 Page 4-11 Section 4.7 19. Is this the exam to be done within 72 hours of release? 17 and 19 seem to overlap. Modified form to have columns fo

days in advance) and Pre-releasModified Section 4.6 to clarify

14 Page 4-11 Section 4.7 22. Change visual to in vision. Text revised per comment.14 Page 4-11 Section 4.7

25. 3ml total or each? Note, elsewhere this document mentions 1ml per blood draw and that only 2 blood draws are required. 

Text standardized to read 3 mL, release.

14 Page 4-11 Section 4.7

New Point, Medical Clearance: The veterinarian has received and reviewed all records on this animal from other facilities that held this animal.

Text revised per comment.

24 Page 5-1 Section 5.1

...second paragraph, the third and fourth sentence should read: "All rescue-related communications and the day to day decision making process in the field are generally handled by the local Field Stations of the Florida Fish and Wildlife Conservation Commission (FFWCC) in conjunction with reports from the public using the 1-888-404-FWCC hotline. All activities related to verification of a report of a manatee in trouble, subsequent rescue, and transport to rehabilitation facilities are communicated throught the FFWCC Field Stations, according to established protocols."

Text revised per comment.

14 Appendix E

Explain how the agency will keep this list and testing requirements up to date so that facilities can easily stay informed. 

NMFS will periodically review this of outside experts such as the WUnusual Mortality Events, and wiwebsite.

14 Appendix G Some formatting issues took place after Appendix G. Unclear of the titles of some pages. Formatting issues have been fixe

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Commenter 

Number Page/Line Section Comment NMFS R

Comments on the Release Criteria

4

However, there are several topics that are not addressed in the current release guidelines. The criteria for immediate release, relocation and release, and post-rehabilitation release should be clarified, as each scenario requires a different type of health assessment. Also, post-release monitoring of animals should be encouraged or strongly recommended when appropriate, and funds to support these activities should be made available. 

In the Final PEIS, Section 6 descworkshop to discuss and outline is a good rehabilitation candidiatemaking immediate disposition derelease or relocation and releaseguidance and training will be planmonitoring of released animals is Sections 3.9, 4.9, 5.9, and 6.8). are available through the John HRescue Assistance Grant Progra

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Section Comment NMFS Response

Water Quality

However, we suggest that care should [be] taken by response personnel to guard against any chemical/medical/fuel spills during the processing of stranded animals (e.g. euthanasia fluids) or their rehabilitation. With this in mind, the FPEIS should highlight that spill prevention best management practices should be established, monitored, and practiced. 

Text added in Sections 5.2.1, 5.3.1, and 5.5.1 would develop spill prevention best managemeresponders to use to reduce the incidence of sequipment, euthanasia solution, etc." 

Carcass Disposal

Although the DPEIS indicates that in cases where a marine mammal carcass is determined to be "toxic" that the carcass may be removed to an approved incineration facility, the DPEIS does not address the sampling procedure to be followed on marine mammal carcasses to determine how the carcass would be considered "toxic". Accordingly, we recommend that the FPEIS indicate what measures will be used to determine the toxicity of the marine mammal carcass.

NMFS has funded, and will continue to fund, retoxicity of carcasses. Currently there is no meimmediately determine if a carcass is toxic. ThAppendix J summarizes the reported informaticoncentrations of Persistent Organic Pollutants marine mammals. NMFS would like use inforknown concentrations of POPs to develop criteuse to best estimate if a carcass may be toxic. 

Cultural Resources

Although the DPEIS states that all work in the area will be halted in cases where undiscovered or unknown cultural resources are encountered, the FPEIS should clarify how this requirement will be communicated to the voluntary Stranding Network members. One consideration could be to have contacting the State Historic Preservation Officer or Tribal Historic Preservation Office be a requirement of the Stranding Agreements or part of annual training for the members of the Stranding Network. Further, the FPEIS should delineate how undiscovered or unknown Tribal Government cultural resources will be handled when discovered during marine mammal carcass burial operations. 

NMFS will encourage stranding network membproactive and contact their state or tribal historofficer or local authorities. In Section 5.4.2, the DPEIS states that if cultuare discovered during burial operations, all wothe State SHPO would be contacted. Any buriNative American/Alaska Native lands would be with Native American tribes, Alaska Natives, oaboriginal peoples. This would include contacHistoric Preservation Officer.

EPA Comments

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Section Comment NMFS Response

EPA Comments

Cultural Resources

In a related matter, it may be prudent to discuss with the Advisory Council on Historic Preservation the possibility of developing a Programmatic Agreement under Section 106 of the National Historic Preservation Act. As the Stranding Network is a "volunteer" based organization, the process to follow in handling cultural resources may not be readily known. A PA would provide the agency with an appropriate process that Stranding Network members can follow to ensure compliance with Section 106.

NMFS agrees that a Programmatic Agreement useful to ensure that Stranding Network membcompliance with Section 106. NMFS will pursunear future. 

Human Health and Safety

The DPEIS does not delineate to any great extent what should be the human health and safety guidelines and practices (especially related to zoonotic diseases communicable to humans: pg 1-7) to be followed for both onsite and off-site disposal of marine mammal carcasses. NMFS should more clearly delineate what the appropriate safety measures are for response personnel (given that some may be untrained volunteers). 

In Section 5.5, protective measures for those iengaged in response and disposal activities arThis includes volunteers. All SA holders wouland safety plan that is reviewed by NMFS. Rewould have adequate protection for the tasks tundertaking. 

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Section Comment NMFS Response

Rehabilitation

NMFS's program should include criteria that clearly 

identify high-priority species (such as threatened or 

endangered species, or species of high 

conservation concern) that quality [qualify?] for 

some measures of human intervention. The criteria 

should also address the sources of debilitation that 

are appropriate to treat (i.e. human-induced versus 

natural). 

Acknowledged

Carcass Disposal

...we concur that the proposed program elements 

are consistent with the Virgina Coastal Resources 

Management Program, provided that NMFS 

complies with all applicable requirements, and that 

no effort is made to dispose of carcasses in 

wetlands.

Acknowledged. Text revised in Section 5, page 5-

3 to state "Burial would not occur in wetland 

areas." 

Response 

The Marine Resources Commission requires a 

permit for any activities that encroach upon, or over, 

or take materials form the beds of the bays, ocean, 

rivers, streams, and creeks which are the property of 

the Commonwealth. If any such activities are 

contemplated, application for and issuance of a 

permit from the Commission will ensure that the 

permitted activity is consistent with the subaqueous 

lands management enforceable policy of the Virginia 

Coastal Resources Management Program. 

Acknowledged

Response 

However, should it be required, any land-disturbing 

activity should be minimized, and access through 

the Chesapeake Bay Preservation Areas should be 

restricted to one point. 

Acknowledged 

Virginia CZM Comments

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