TheTestimony of Dr. George R.
Harker in response to PEIS described below
regarding the research and
enhancement program for Hawaiian monk seals in the Hawaiian Islands.
(For PDF copy of the testimony click here
Further PEIS testimony of Dr. George R. Harker. Thirty-four pages of
field notes and the annotated listing of raw video's
covering the growth of Koki the Monk Seal born October 9, 2009 just
outside Hana, Hawaii. The most comprehensive
look at the growth and development available on a Hawaiian Monk Seal
ever. PDF copy of Some
a Monk Seal Mother and Pup, Field Notes of Observations of Hawaiian
Monk Seal (Monachus schauinslandi) click here
(NOAA), National Marine
Fisheries Service (NMFS),
Pacific Islands Regional Office (PIRO) is
proposing to implement specific management actions and administer
associated research and enhancement program for Hawaiian monk seals in
the Hawaiian Islands. Public
comments were due by November 15, 2010.
NMFS has decided to allow additional time for submission of
comments on this action (75 FR 69398-69399). The scoping period for the PEIS is extended
November 30, 2010. Written comments must be received or postmarked
by November 30, 2010.
opportunity to express your views and
identify issues to be addressed in
the Programmatic Environmental
Impact Statement (PEIS). In accordance with the National Environmental
Policy Act (NEPA), NMFS requests any comments you may have about
potential management actions
and associated research and enhancement
program activities that may be performed on Hawaiian monk
seals in an
effort to recover the species.
Testimony of Dr. George R. Harker regarding the Notice of Intent to
Prepare a Programmatic Environmental
Impact Statement on Implementing
Recovery Actions for Hawaiian Monk Seals
Submitted November 12, 2010 by email and mail.
Proposed Action and Possible Alternatives
This notice initiates a public scoping period that
will help determine the structure of each alternative considered
PEIS. NMFS has identified the proposed action and several other
alternatives, including the No Action Alternative.
The final scope and
structure of the alternatives will reflect the combined input from the
public, research institutions,
affected State and Federal agencies, and
NMFS administrative and research offices. The number and structure of
alternatives that are analyzed in the PEIS will be determined at a
later date. Themes to include in the range of potential
are presented here to provide a framework for public comments:
No Action Alternative: Under this alternative,
currently permitted research and enhancement activities on Hawaiian
monk seals would continue until expiration of the permit in 2014 (NMFS
ESA-MMPA Permit No. 10137-04 issued
to the NMFS Pacific Islands
Fisheries Science Center). Recovery Plan actions authorized by this
permit would not be
implemented beyond 2014. Currently, the existing
research and enhancement activities include, but are not limited to:
1. Population assessment (e.g., counting,
resighting, marking for identification, flipper tags); Some
population assessment. With the low numbers in the main
Hawaiian Islands it should be relatively easy to get a handle
existing population. It is quite conceivable that each seal can be
photographed and identified by its natural markings.
released on http://monksealmania.blogspot.com/ support this premise..
Obtaining this information directly from NOAA has been unsuccessful)
Bleach marking seals is not necessary for this
reason. Additionally most seals have flipper tags which can be readily
seen on a hauled out resting seal and can be easily
routinely publishes tag photos
of seals that it encounters.
There is much data on the numbers of Monk Seal that
needs to be assessed. Information published on monksealmaniablogspot.
suggest that a great deal of information on the number and movement of
seals is known and just needs to be analyzed and reported.
There is no need for the biannual counts. A spot
check at a particular time does not really provide any useful
With information known on most every existing seal in the
Main Hawaiian islands, including births what is needed is the
availability of this information to the public or interested scientist.
The literature suggest and NOAA asserts Monk Seals
are “Sensitive to disturbance.” The elimination of marking
that are redundant and lead to confusion, i.e. such as bleaching should
be eliminated. Bleach markings have
to be renewed annually since the
seal molts.MonkSealMania accounts reveal that there can be confusion
caused by this
and the legibility of the numbers themselves. I
personally have been mislead by the bleach markings on a seal that I
that I did not know had been marked. I also note that obtaining
information from NOAA about marked seals had been
difficult. Then of
course there is the aesthetic question, do we want to see our loved
critically endangered Monk seal defaced by a brand?
2. Health and disease studies (e.g., tissue
sampling, morphometric measurements); It appears that a lot of
useful information is being collected.However, it also
appears that much of this information is not readily available to the
or scientific community. To my knowledge there are no published
proceedings from annual stranding conferences where this material is
presented and discussed.
3. Foraging studies (e.g., telemetry, scat
collection); The telemetry component posses an unacceptable risk to
The presence of the device on the seals back has the potential
to snag on fish lines or nets, underwater rock out cropping
seal might attempt to squeeze through. MonkSealMania Bog (http://monksealmania.blogspot.com/
reports of such entanglements and/or the tearing off of
transmitters by unknown causes. One can only speculate on the
circumstances surrounding the removal of these transmitters and forces
that needed to be exerted to break free.
I am reminded of efforts to
collect data during WW II on aircraft loses due to taking enemy fire.
Records were made
damage to returning aircraft. At some point it was realized that it was
the part of the plane where they had no record
of damage that was the
vulnerable part that needed attention. How many seal with transmitter
in place have not been seen
lately and should be presumed lost rather
than swimming around with a dead battery?
An analysis should be made of what is happening to
the devices. Are they being scraped off by the animal? Are they
snagging on underwater obstructions or other elements within the
environment the seal. Remember that the streamline
capabilities of the
seal evolved and remained relatively unchanged for over ten million
years. Any change in the hydrodynamic
condition of the seals body shape could have a profound implication on
its survival value.
Again note that Monk Seals are “sensitive to
disturbance.” No doubt the seals are reacting to these devices and
adjusting their behavior to deal with the issue. The question of course
is whether that adjustment will be
beneficial or detrimental to their
survival as a species.
4. De-worming research (e.g., fecal samples, testing
treatments); This is another area where the work that has or is being
done is limited in its
availability. Techniques that are intrusive to the animals should be
evaluated. Results of
completed or ongoing research needs to be published and made available
to the public and
5. Translocation of weaned pups within the NWHI to
survival; There is no need for translocation of weaned pups to improve
juvenile survival. Mother
nature has responded successfully to shifting impacts on Monk Seal
populations for over ten
million years. Shifting freshly weaned or any young juvenile seal is
counterproductive because it
curtails the learning process of the seal with its mother and other
members of its extended family
i.e. the rest of the seals in its initial habitat.
Translocation and interference with seal pups has
had clearly negative impacts that most
people are probably not aware of.
KP2 as example of translocation of unweaned pup. KP2
was removed from his mother
because she allegedly abandon him. He had been observed trying to
suckle a rock and mother
was observed biting him on the face .within a day or two of
birth. I note that the literature
suggest that it may take a few days for the newborn seal to find a
nipple ( citation here to be
added Monk Seal in University course notes)
Filming Koki at ten days old I recorded him
approaching a ocean rock clearly suggesting
that he thought he was approaching his mother. This is recorded in raw
data videos of Koki taken
on October 19, 2009 when he was ten days old. In this and virtually
every other video it is not
uncommon to see the two interacting by “biting” each other on the face.
Snatching KP2 to improve his chance for survival?
Supposedly KP2 was snatched because he was too
friendly. Then the “discovery” of
cataracts precluded his being returned to the wild. As I understand
things from the 4 th Annual
Stranding conference June 2-4 of 2009, KP2 developed the
cataracts under the care of National
Marine Fisheries Services when he was incarcerated after being
allegedly abandoned by his
mom. It was reported at the session Hawaiian monk seal “KP2" by Dr.
Gregg Levine that there
were a number of cases of seals developing Corneal Edema. It is quite
common for marine
mammals in captivity to develop this and subsequently go blind.
It has come to my attention that many of the marine
mammals held in captivity around
the world are actually blind suffering from eye effects such as
cataracts due to problems
associated with their confinement.
KP2 is the poster child for a completely failed Monk
Seal Restoration Program. I am
fearful that it will not be to far in the future when I take my
grandsons to n aquarium to see the
last living Monk Seals. In my mind I can hear the dialogue, “Yes,
son that is what a live monk
seal looks like. You were lucky you got to see the Koki the monk seal
grow up in the video.
When he died there were about a thousand alive. Today there is just
I suppose the good point of a seal incarceration is
that one can get a much better view
than one can have in the wild if complying with the NOAA directive of
150 feet. Plus you can
make eye contact!
Problems with removing any pup (weaned or otherwise) from parent. Part
of growing up is
learning information essential for survival from the parent. NMFS
suggest that Monk Seals tend
to be solitary animals living in isolation. They suggest that the
mother in rearing the pup mostly
nurses the pup on the beach. After feeding the pup for 5 to 7 weeks mom
supposedly leaves the
pup to fend for itself.
Observation in the field and reviewing the material posted on
Monksealmania.blog show this is
not the case. Mother is constantly working with the pup to teach it the
skills necessary for
survival. This process does not stop with weaning. Contrary to NMFA’s
statements to the
contrary, the mother still interacts with the pup. Indeed the pup
is part of the extended seal
family. And through its life it will interact and learn from its
Koki’s mom, RO 15 experienced significant trauma at the hands of NOAA
that may explain
aspects of her behavior. Her daughter, “RO 42", was captured and
removed from the main
Hawaiian Islands in February 2009. This occurred eight months prior to
Koki’s birth on Maui.
There is no doubt that RO 15 knew this occurred, one wonders if this
had an effect on mom
going from the Big Island to have pup number eight on Maui.
NMFS had intensive coverage of that event on Maui. Volunteers manned
barriers and kept up a
constant barrage of activity and chatter in close proximity to the
seals. About half way through
the raising, mom moved the pup off the beach and down the coast to a
nearby fish pond. (A
review of Monksealmania.blog which reports observations on a number of
seal pupping on Oahu
and Molokai does not report any relocation of pups to a different
permanent location that I could
NMFS personnel moved barriers and the general commotion of their
outreach program to close
proximity to the seals at the fish pond. Surveillance continued with
much interaction between the
volunteers and the seals. This occurred 24/7 for two months.
Koki the pup was ultimately tagged and also had a transmitter placed
upon his back. In April the
last transmission was received. He has not been seen or heard from
since that time.
A word about tagging and transmitter placement. How traumatic is this
process to the seal? In
each case four or more people grab the seal and hold it while tags are
attached to rear flippers or
transmitter is glued to back. I have heard accounts attributed to
people involved in the capture
that it was such an unpleasant experience for the captor that they did
not want to do it again.
Presumably they were reacting to the vibes given out by the struggling
In the period between his weaning and disappearance, he was
occasionally seen sharing a beach
with his mother. Similar interaction between offspring and their
parents is reported on
Jumping to October 2010 we find that mother RO 15 has returned to the
Big Island. Last
information made available to me by NOAA-NMFS is that the seal is
fourteen miles up a river
stream which is difficult to reach. The obvious question is what has
brought this extraordinary
change about in her behavior? Is it the actions by NOAA-NMFS?
Where seal choose to birth has tremendous implications for the survival
of the species. The
Mediterranean Monk Seal was inclined to birth in surface shoreline sea
caves rather than open
beaches. Tidal shifts and other natural phenomena resulted in the loose
of a significant number of
pups. This observation is based on material presented in the website:
6. Mitigation of fishery interactions (e.g.,
disentanglement, removal of fishing hooks);
and Over the past few years I have been aware of a
number fishing hook ensnarement. From
what I have heard and observed most such hooking resolve themselves
intervention. (Koki had two at one point)
A number of entanglements documented by
MonkSealMania involve lines and other
material entangled on the transmitter packs stuck on the backs of the
creatures. Seals have
evolved a smooth coat and sleek body shape that is effective in cutting
through the water and past
obstructions such as rock outcroppings and vegetation entanglements.
The addition of these man
made impediments is not supportive of increasing survival rates.
7. Mitigation of adult male aggression (e.g.,
removal and relocation of aggressive males).
I doubt it this has any significant effect on Monk Seal survival. Ten
million years of successful
interaction between the sexes of Monk Seals pretty much tells the story.
Status Quo Alternative: The Status Quo
Alternative would consist of the existing types and
scope of management, research and enhancement activities (including
those identified in the No
Action Alternative). New permits would be issued to maintain the
current levels of research
and enhancement activities. Existing management activities include but
are not limited to
protecting seals that haul out on recreational beaches and creating
messages, brochures, signs and volunteer programs to minimize human
and other adverse impacts.
There are a number of problems with the continuation of the Status Quo
Alternative which are
quite serious and need to be addressed immediately.
1) Existing management activities include but are not limited to
protecting seals that haul
out on recreational beaches. The current existing management
activity intended to protect the
seal haul out on recreational beaches is the main form of harassment
experienced by the seal
whether on a recreational beach or any other location known to
Ironically it is the existing management activities
intended to “protect” the haul out of
seals on recreational beaches that is significantly changing the
character of these encounters
between traditional beach users such as people and monk seals. Prior to
the haul out of a monk seal was a rather non event. A hauling out seal
might attract attention to a
few in proximity to the event. But most beach users would be unaware.
Today “volunteers” or NOAA employees descend on the
scene and force through threat
of law that people back off from the seal one hundred and fifty feet.
It is suggested that this
protective corridor is necessary for the benefit of the seal.
By placing stakes and yellow ribbons boundaries are
defined that while intended to effect
people also tend to define and restrict the movement of the seal.
The extent and level of animosity created in the
beach visitor is generally not known and
usually not reported.
MonkSealManiaBlog reports on the actions of their
volunteer posse and the number of
seals they “protect.’ One incident that particularly struck me involved
a volunteer who had
engaged some children and their parents in a discussion about their
intrusion inside the signs to
approach a sleeping seal. After the conversation someone in the crowd
threw a rock with such
force that the man was brought to his knee’s The rock struck above and
behind the temple. I
believe this volunteer is lucky to still be with us.
Monk seal as Aumakua. Many if not all of native Hawaiian’s share a
connection with various
creatures in their environment including sharks, turtles and monk
seals. They view a particular
animal or thing as their deified ancestor. I have had a number of
Hawaiian’s tell me they view the
monk seal in this way. NOAA’s admonition that people can not
interact, feed, or touch a seal
runs contrary to this very fundamental aspect of Hawaiian culture.
A link and bond to a monk seal or indeed any other
creature on earth and humankind is a
basic and given condition of the universe. This connection between
things can not be disavowed
or interfered with by anyone without dangerous consequences.
Note RH 44 lost pup on Maui April 2009 Had prior pups on Moloki and
went back 2010 to
have successful pupping. This I believe is a very significant
event in the context of Monk Seal
survival and it should not go unnoticed and further study should be
made of the circumstance
surrounding this event
2) creating effective outreach messages, brochures, signs and volunteer
minimize human disturbance and other adverse impacts.
Outreach messages, brochures, signs and volunteer programs intended to
disturbance and other adverse impacts actually work to the contrary.
A great deal of information contained in the
brochures or distributed by NOAA is
incorrect if compared to actual information collected by scientist and
often presented at NOAA
conferences. Unfortunately these documents are not readily available to
the scientific community
let alone the general public.
It is rather paradoxical that the “outreach
messages, brochures, signs and volunteer
programs to minimize human disturbance and other adverse impacts” is
the main human
disturbance with regard to the Monk Seal.
1) a sleeping Monk Seal often goes unnoticed. A
sleeping Monk Seal surrounded by
yellow tape and other signs is hard to ignore.
2) much of the material presented by the volunteers
is incorrect. ie, the idea that these
seals do not congregate in colonies like other seals,
3) what is the impact of the signage and resulting
attention from the volunteers and the
puplic. Numerous data exist that could be analyzed to get a handle on
4) Signage stating the seals will bite when that is
indeed highly unlikely without serious
Enhanced Implementation Alternative (Proposed
Action): The Proposed Action would
result in implementation and continuation of activities identified in
the Status Quo, as well
as additional activities to achieve more comprehensive Recovery Plan
These additional activities would include, but are not limited to:
1. Vaccination studies (including potential
vaccination); The data regarding death to such
items as Taxoplasmosis and other diseases should be examined. Just a
cursory look at published
material suggest that this is an issue that is being overblown. The
number of deaths attribute to
diseases picked up from dogs and feral cats appears to be
insignificant. The fact that the seals are
still here in the face of the interaction between dogs and cats for
many, many years suggest this is
not a problem.
2. Aversive conditioning (e.g., the development of
tools to modify undesirable seal
behavior including interactions with humans or domestic animals); There
is little data to
suggest that there are tangible problems with the interactions between
seals and with humans or
domestic animals. That posse a risk of extinction ... question the need
for seal behavior
medication when the real risk stems from the actions of humans directed
toward the seal. The
Navy’s use of sonar would be a good example.
3. Archipelago-wide translocation to improve
juvenile survival; and Moving juveniles that
have not had the benefit of rearing within the seal community is
replete with all sorts of
.What is the level of problems with “worms?” Before deworming I would
suggest the further
collection od data and an effort to determine the nature of threat to
the seal population.
The PEIS will assess the direct, indirect, and
of implementing the alternative approaches for funding, undertaking,
and permitting the management, research and enhancement activities on
Hawaiian monk seals as well as other components of the marine ecosystem
and human environment. Anyone having relevant information they believe
NMFS should consider in its analysis should provide a description of
that information along with complete citations for supporting
Hawaiian Monk Seal Surfer Girl Hauls out south Lahaina
Monk Seal Interaction with Snorklers
Monk Seal at Marine Sanctuary Fish Pond
Molting Monk Seal RH 44
Hawaiian Monk Seal Skeleton
Monk Seal RH44 Water Snoozing
Monk seal meets Surfer Dude
Koki Hawaiian Monk Seal Sixty Three days old
Koki Monk Seal Documentary Play List
Koki Monk Seal 63 days in three minutes
Koki Monk Seal 45 days old
Monk Seal Feeding
Monk Seal Haulout January 25, 2008 Makena State Park
Monk Seal Human Interaction (YouTube Playlist)
Koki Hawaiian Monk SealPup (YouTube Playlist)
Website Koki Monk Seal Documentary
Recommendations and Conclusion:
The role of NOAA -NMFS should be the collection and dissemination of
the nature and status of the Monk Seal.
Data collection should be as non intrusive as possible. Techniques
currently used are most
invasive and are clearly causing adverse effects.
1) Telemetry devices on back imped motion through the water. They snag
on things such as
fishing lines, nets, and other underwater obstructions. Some
researchers (including myself)
believe that deaths have resulted.
2) Removal of animals from their environment. The removal of young
animals has a traumatic
affect on the mother and the population. In the case of RO15 after the
removal her daughter she
changed her birthing site. After seven pups on the Big Island she move
to Maui. After problems
there she returned to a very remote inland location on the Big Island.
3) The removal of KP2 from his mother may be based on the incorrect
interpretation of nursing
behavior. Nevertheless the results were extremely detrimental to the
creature. He developed
cataracts which is quite common for marine creatures in confinement. He
did not develop the
socialization skills associated with his species because he
lacked parental direction which is so
apparent in the rearing process. (NOAA -MSFS apparently is not fully
aware of this phenomena
and suggest the relationship between pup and mother is very tenuous and
limited before and after
weaning. Video documentation by this author suggest a much different
4) The current pro active outreach program built around cordoning off
resting seals should be
eliminated. It generates a tremendous amount of animosity toward seals.
People spend big money to
come to Hawaii and find their beach access interfered with. Locals are
right, the seals are part of their
natural environment and they understand their relationship with
Respectively submitted November 14, 2010
Dr. George R. Harker
This is a collection of videos that document the life of Koki a monk
seal born on Koki Beach out of Hana on the island of Maui. What makes
unique is that Koki narrates them. He does this by channelling through
Dr Leisure. The embedded video is a playlist of a
that appear on YouTube.com.