Comment from Phillip Dale

Thank you for the opportunity to comment on this potential designation. In nature, all populations fluctuate over time depending on a myriad of variables, Beluga Whales are not immune to this natural fluctuation. Population counts have only occurred since 1994 and although there is fluctuation the numbers appear to be relatively stable. This does not show a great downward trend and anecdotal estimates from the 70’s is not enough evidence to allow for significant rule changes. Yes, South Central Alaska and the areas around Cook Inlet have grown and changed significantly over the last 50 years but the actual development in the inlet has been fairly constant for the last 40 years while whale populations have fluctuated up and down and don’t seem to have significantly changed in the time period the population has been monitored. I don’t believe that listing the upper inlet and Kachemak Bay as critical habitat under the ESA is going to significantly aid the Beluga population while it will add significantly to the regulatory morass. If NOAA has identified specific needs to aid the Beluga population then that should be considered, but just blanket regulations under the ESA is not necessary nor has it proven effective in other species. Thank you again for this opportunity to comment, Greg Dale