My letter to Congress Regarding H.R. 9621. 

Dear Members of Congress,

I am writing to urge you to oppose H.R. 9621, the Northwest Endangered Salmon Predation Prevention Act of 2026.

I am a marine biologist with more than 30 years of experience studying marine mammals in the field, including extensive experience in the Pacific Northwest. I have spent much of my career observing marine mammals within the context of functioning marine ecosystems, and I strongly support eIective salmon recovery. I come with more than 30 years of experience in producing international wildlife documentaries and education films including for NOAA.

My concern with H.R. 9621 is not that pinnipeds do not consume salmon. They clearly do. The concern is that the legislation appears to assume that reducing pinniped abundance will necessarily result in increased salmon survival.

The available science does not establish that conclusion. 

In fact, the Washington State Academy of Sciences (WSAS), in a comprehensive scientific assessment commissioned by the Washington Department of Fish and Wildlife, identified substantial uncertainties surrounding pinniped predation and its effects on salmon recovery (Pinniped Predation on Salmonids in the Washington Portions of the Salish Sea and Outer Coast, Washington State Academy of Sciences, 2022). The Academy emphasized the need to understand the entire ecosystem and cautioned against assuming that localized observations of predation can be generalized across the region. 

That distinction is critical as Congress considers expanding lethal take of pinnipeds across Washington waters.

1. The central scientific question is not whether pinnipeds eat salmon. It is whether removing them will increase net salmon survival.

This is the question Congress should require proponents of H.R. 9621 to answer. 

Pinnipeds are predators, but they are not simply salmon predators. Harbor seals and sea lions consume a wide diversity of prey, and their interactions with salmon occur within a much larger and more complicated food web.

The WSAS assessment identified substantial gaps in our understanding of these interactions and concluded that there is an urgent need to understand how the ecosystem operates before making broad management decisions. 

Consequently, the number of salmon observed being consumed by seals or sea lions cannot, by itself, tell us whether removing those predators will increase the number of salmon ultimately surviving to reproduce.

That requires an assessment of net ecological effects.

2. Pinnipeds consume fish that themselves interact with salmon.

Pinniped diets include numerous fish species, including species that prey upon juvenile salmon.

This creates an important trophic interaction that is easily overlooked when salmon predation is considered in isolation.

If a harbor seal consumes an adult salmon, that is a direct and visible mortality event. But if that same seal consumes fish that prey upon juvenile salmon, the ecological consequence is very different.

The latter interaction is considerably harder to observe, particularly in turbid estuarine environments. Yet it may be biologically important.

This is why scat analysis and other diet studies are so valuable. They provide a much broader picture of what these animals are removing from the food web than observations of seals or sea lions visibly consuming salmon.

The question, therefore, should not be: How many salmon do pinnipeds eat?

It should be: What is the net effect of pinnipeds on salmon survival across the entire food web and across all salmon life stages?

That question remains insufficiently resolved.

The WSAS report specifically identifies uncertainties surrounding these trophic

interactions and the difficulty of predicting ecosystem-wide consequences from changes in pinniped abundance.

3. Broad lethal removal could redistribute or even increase predation rather than reduce salmon mortality. 

Marine mammals respond behaviorally to repeated human disturbance and lethal activity. Animals subjected to intense disturbance can alter their use of resting and feeding areas, change travel patterns, and avoid locations associated with danger. In the worst case this could lead to an increased up-take of prey and higher salmon mortality with the surviving pinniped population spending more energy swimming and foraging while getting less rest.

Hunted predator population often require more energy per animal as a direct result of avoiding lethal action. H.R. 9621 would substantially expand the geographic scope in which lethal take could occur. Removing or displacing pinnipeds from one location does not necessarily mean that their ecological role disappears. Animals may redistribute their movements and foraging into other areas.

The outcome of measure H. R. 9621 could be a change in location and timing of predation by targeted pinniped colonies rather than a proportional reduction in salmon predation and often requires higher energy demands of individual pinnipeds resulting in increased overall predation by the remaining population.

There is an important distinction between demonstrating that a particular site has high pinniped predation and demonstrating that removing pinnipeds from numerous sites across a large ecosystem will increase total salmon survival.

The latter requires evidence that we do not yet possess at the necessary scale.

4. This is precisely why targeted management is different from broad lethal take.

There may be legitimate circumstances in which targeted pinniped management is warranted.

Artificial structures such as certain dams, weirs, and other fish-passage bottlenecks can concentrate predators and prey in ways that do not occur under natural conditions. In such situations, carefully designed, site-specific management can be evaluated by measuring whether salmon survival improves. That is fundamentally different from authorizing expanded lethal take across Washington waters.

At a genuine bottleneck, the scientific question can be relatively straightforward:

Does removing or deterring pinnipeds at this location measurably increase salmon survival?

A broad regional program presents a much more complicated question: What happens to the entire food web when pinniped abundance and distribution are altered across multiple locations?

The second question is precisely where the scientific uncertainties become greatest.

The WSAS assessment was commissioned to examine these issues and concluded that substantial uncertainties remain, emphasizing the need for system-level research and management interventions rather than simply extrapolating from smaller-scale studies.

5. Broad pinniped removal could have consequences for Bigg's killer whales.

Congress should also consider what happens higher in the food web. 

Bigg's killer whales are specialized marine-mammal predators whose prey includes harbor seals and sea lions. They are an important and increasingly visible component of the Salish Sea ecosystem.

Reducing pinniped abundance across broad areas could therefore aIect the availability and distribution of prey for these killer whales.

This is not simply a theoretical concern. The broader ecological consequences of changing pinniped populations are part of the uncertainty that must be considered when evaluating management actions.

An ecosystem-based approach should ask not only what happens to salmon when seals are removed, but also what happens to the predators that naturally regulate seal and sea lion populations.

6. Broad pinniped removal has consequences for wildlife experiences of residents and visitors to the Pacific Northwest with real income consequences.

Harbor seals and sea lions are part of the charismatic megafauna the Pacific Northwest has to oIer and have become accustomed to human vicinity.

More than five decades of Marine Mammal Protection act have led to a carefree trusting relationship between these pinnipeds and humans up and down the US west coast.

Boaters, kayakers, wildlife safaris, photographers, locals and returning visitors have all become accustomed to being able to view these marine mammals at close range. Much like the orcas they are featured in advertisements and have a place in the hearts of millions of people.

Extended lethal action as expressed in H.R. 9621 would not only quickly end the amazing wildlife experiences people can have with these pinnipeds in our region, it would also lead to a significant push back against this measure by millions of voters and taxpayers. 

The measure will likely have a negatively aIect to income of wildlife safaris

and tourism when part of the charismatic wildlife no longer becomes available for viewing.

I have personally worked in countries such as Norway where seal hunting is a regulated legal reality. Seal populations have all but retreated into remote regions or islands and are notoriously shy and diIicult to see. They are no longer part of the charismatic megafauna people can enjoy and experience.

7. Salmon recovery cannot be reduced to a single predator-prey relationship.

Salmon encounter mortality and habitat limitations throughout their entire life cycle.

Fish passage barriers, including dams and culverts, have restricted access to spawning and rearing habitat. Juvenile salmon also face substantial challenges during downstream migration.

Degraded riparian habitat, loss of nearshore habitat, water-quality degradation,

stormwater contamination, changing freshwater conditions, and climate-related changes in temperature, precipitation, snowpack, and streamflow all aIect salmon survival.

Contaminants such as 6PPD-quinone, petroleum-related pollutants, and other urban and agricultural contaminants add additional pressures.

These factors do not mean pinniped predation is irrelevant. They mean that salmon recovery requires addressing the full suite of factors affecting survival rather than treating one highly visible predator as a proxy for a much larger ecosystem problem.

8. We should not confuse what is easy to observe with what is most important ecologically.

This may be the most important point for Congress to consider.

It is easy to see a sea lion eating a salmon.

It is much harder to see a seal consuming demersal fish in a turbid estuary. It is harder still to quantify how that predation affects juvenile salmon survival weeks or months later. 

Ecology is full of these indirect effects.

A management decision based primarily on what is easiest to see risks producing a distorted picture of the actual food web.

That is why the WSAS assessment is so important. It was specifically undertaken to examine the scientific basis for concerns about pinniped predation and salmon recovery, and its conclusions emphasize substantial uncertainty and the need for better ecosystem-level understanding.

9. Congress should apply the precautionary principle to broad lethal removal.

I am not arguing that pinniped predation should never be managed.

I am arguing that the scale and scope of management should be proportional to the strength of the evidence.

Where demonstrated bottleneck exist and a scientifically testable intervention, targeted management may be appropriate.

But expanding lethal take across Washington waters before demonstrating that doing so will produce a net increase in salmon survival is a very different proposition. If the objective is salmon recovery, Congress should demand measurable evidence that the proposed action will accomplish that objective - not simply evidence that pinnipeds consume salmon.

The distinction matters.

We already know that pinnipeds eat salmon.

We do not know with sufficient certainty that broadly reducing pinniped populations will produce the desired ecosystem-level increase in salmon survival.

Indeed, the Washington State Academy of Sciences has identified substantial

uncertainties in precisely these ecological relationships and has emphasized the need to understand the entire system when considering management interventions.

A better path forward:

I urge Congress to reject H.R. 9621 in its current form and instead support broad measures which are known to improve salmon survival.

Where pinniped predation is demonstrated to be a significant problem for salmon survival at an artificial bottleneck, management should be narrowly targeted and accompanied by rigorous monitoring of whether salmon survival improves. Simultaneously strategies to remove these artificial bottlenecks and/or significantly improve fish passage and clean water at these sites

should be explored and implemented.

At the broader ecosystem level, we need substantially better information about pinniped diets, predator-prey interactions, salmon life-stage mortality, redistribution of predators following disturbance, and the indirect effects of changing pinniped abundance. 

Most importantly, we should continue addressing the well-established causes of salmon decline: toxic substances in stormwater run-off, impaired fish passage, habitat degradation, nearshore habitat loss, and climate-related changes to freshwater and marine ecosystems.

We should not make a sweeping ecological intervention based on an assumption that the science itself has not established.

As a marine biologist with more than three decades of field experience studying marine mammals, I believe strongly in evidence-based and holistic wildlife management taking all aspects of the food web into account. I also believe that good science requires us to acknowledge uncertainty rather than fill it with assumptions.

H.R. 9621 risks doing precisely that.

Please protect salmon recovery efforts from becoming overly focused on a single, highly visible component of a complex ecosystem. Require the evidence necessary to demonstrate that broad pinniped removal will increase salmon survival before authorizing such an expansion of lethal take and consider the many consequences such a measure would trigger.

Salmon recovery deserves nothing less than the best available science.

Sincerely,

Florian Graner, Ph.D.

Marine Biologist