Support New Protections for Hawaiian False Killer Whales

Dear Regulatory Branch Chief,

The undersigned individuals strongly support expanded protections for Hawaiian false killer whales in the Proposed False Killer Whale Take Reduction Plan (RIN 0648–BA30). Specifically, we support immediate implementation of the proposed rule, including a year-round closure of the tuna longline fishery in essential habitat for the Hawaiian insular false killer whale, and the proposed Southern Exclusion Zone.

We are concerned that the determination to close the Southern Exclusion Zone is not based on the most transparent and conservative estimate of Potential Biological Removal (PBR) of false killer whales, and we recommend that the rule be modified to ensure that PBR is never exceeded.

Fisheries other than Hawaiian deepset tuna longlines seriously injure and kill imperiled false killer whales, though currently at lower levels than the tuna fishery. Observed interactions from all fisheries in the whale habitat must be included in the final management plan and PBR calculation. We recommend that the triggers for closing the Southern Exclusion Zone be implemented based on the cumulative total interactions of all fisheries. The impacts of shallowset longline, short-line, and kaka-line fishing gear types are of greatest concern.

We support “weak hook” requirements, and request additional research to determine if “weaker” and smaller hooks can be required in the future to better protect these whales.

To ensure recovery of false killer whales, we also recommend:
• more research to identify additional fishing areas for closure;
• reduced deepset longline fishing effort;
• further research to validate and improve the effectiveness of “weak” circle hooks; and
• immediate implementation of all new protections.

Thank you for the opportunity to comment on our support and the need for improvements to the Proposed False Killer Whale Take Reduction Plan.

Sincerely,