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 Observations on
a Monk Seal Mother and Pup, Field Notes of Observations of Hawaiian Monk Seal (Monachus schauinslandi) click here


The National Oceanic Atmospheric Administration (NOAA), National Marine Fisheries Service (NMFS),
Pacific Islands Regional Office (PIRO) is proposing to implement specific management actions and administer
the 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
public comments on this action (75 FR 69398-69399). The scoping period for the PEIS is extended to
November 30, 2010. Written comments must be received or postmarked by November 30, 2010.


The Scoping period provides an 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
 in the 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 the
alternatives that are analyzed in the PEIS will be determined at a later date. Themes to include in the range of potential
alternatives 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 observations on
population assessment. With the low numbers in the main Hawaiian Islands it should be relatively easy to get a handle
on the existing population. It is quite conceivable that each seal can be photographed and identified by its natural markings.
 (Data sheets 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
 documented with telephoto lenses.  http://monksealmania.blogspot.com/ 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 information.
 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
techniques 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 knew
 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 interesting and
 useful information is being collected.However, it also appears that much of this information is not readily available to the public
 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 seals.
The presence of the device on the seals back has the potential to snag on fish lines or nets, underwater rock out cropping
which the seal might attempt to squeeze through.  MonkSealMania Bog (http://monksealmania.blogspot.com/) has numerous
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
of the 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 anti-parasite
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
scientific community.

    5. Translocation of weaned pups within the NWHI to improve juvenile
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 KP2.”
    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 associates.

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 animal.

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
MonkSealManiaBlogspot. (http://monksealmania.blogspot.com/)

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: http://www.monachus-

    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 without human
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 effective outreach
messages, brochures, signs and volunteer programs to minimize human disturbance
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 NOAA.        
    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 NOAA’s involvement
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 programs to
minimize human disturbance and other adverse impacts.    
Outreach messages, brochures, signs and volunteer programs intended to minimize human
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 this topic.
    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 implementation.
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

    4. De-worming.
.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 cumulative effects
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 information regarding
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 story.)

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 them.    

Respectively submitted November 14, 2010

Dr. George R. Harker   



Hawaiian Monk Seal (Monachus schauinslandi)

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 them unique is that Koki narrates them. He does this by channelling through Dr Leisure.  The embedded video is a playlist of a series that appear on YouTube.com.

Dr. Leisure® P.O. Box 1137, Kihei, Maui, HI 96753 
phone: 808-250-4160 
e-mail: DrLeisure1@aol.com
World Wide Web: http://www.drleisure.com/

Dr. Leisure is the trademark of internationally known cyberspace philosopher Dr. George R. Harker who resides on Maui. 

Entire contents are copyright by Dr. George R. Harker 1997 -- 2010