ADMINISTRATIVE LAW JUDGE                                                                            June 24, 2019
THE HONORABLE GEORGE J. JORDAN
Docket No. 19-NMFS-0001

Dear Honorable Judge Jordan,
This e-mail communication serves as a letter of request by the Peninsula Citizens for the Protection of Whales (PCPW) to Extend the Hearing Schedule in Docket No. 19-NMFS-0001. We have electronically served this communication on all Parties who have provided email addresses.
Specifically, PCPW respectfully requests that the hearing date in this matter be rescheduled from beginning on August 12, 2019 to beginning on September 16, 2019.                                               
 We have known for many years that the EIS analysis we had hoped for would end in a courtroom-like setting, in front of a judge. It was hard to imagine participating in such a legal arena , but we had read that the hearing would take place “in the affected area”. We took that to mean that this critical  process would occur here, in Port Angeles, convenient for all the Olympic Peninsula residents , tribal and non-tribal, who will be most impacted .  Port Angeles is not short of venues, and the National Marine Fisheries Service (NMFS) has held numerous scoping and public meetings associated with the National Environmental Policy Act / Environmental Impact Statement documents here. We were relieved to believe that this complicated process would at least unfold close to home.  When the location and date were published, we were surprised that Seattle was the location.  Nevertheless, we were sure we could manage to be there on August 12. When it became apparent that August 12 was just the starting date of a potentially lengthy, open-ended hearing, we became very concerned. On June 2, 2019 we sent a request for postponement to NMFS / service list. We admitted that our lack of experience had led us to a naiive assumption that this hearing would be handled in a single day, August 12.  It now seems dubious to us that the issues involved can even be dealt with in a single week. The specific problems for us with the August 12 starting date are these:
�	August is the peak of tourism season everywhere on the Olympic Peninsula. Having served on the Olympic Peninsula Visitors Bureau (OPVB) Board of Directors for many years, and the Juan de Fuca Scenic Byway Association board for 18 years or so, I know this to be the case -beyond my own observations at the Joyce Depot Museum. I also understand very clearly from my tenure on the OPVB board, the crucial economic impact these few months of summer weather have on the local economy. I have been employed at the Joyce Depot Museum since 2004 , and I have been the only employee at the museum since then.  Nine months of the year this job is very part time, as the museum only opens on Saturdays from September through May. There are only three months when the museum is open four days per week: June, July, and August.  Even at minimum wage, this increased summer income is extremely important to augment  my household 's small Social Security income.  And my presence at the museum during the summer months is never more vital than in August. This is the time when tourism visitation peaks, and many pioneer descendants and researchers come to Joyce to be guided through our archives for answers to their questions. I greet many hundreds of visitors in August alone.  For me to be gone from my post anytime in August will certainly frustrate and disappoint many people, including my employer, as I have no replacement with any experience to handle this responsibility.
�	A related problem for me is the high cost involved in staying in Seattle for a week or more during peak tourism occupancy. We weren't worried about the August 12 date, as that could have been managed as a day-trip.  The “week of August 12” is another matter entirely.  I cannot commute from home, as we are a 3-4 hour drive, plus ferry ride, to downtown Seattle. In August , traffic and ferry lines are predictably backed up. But to stay in Seattle for a lengthy hearing would be an unbearable expense , for which we are not prepared.  We are quite sure that more affordable lodging will open up in September. A check of a room-booking website shows hotel rates in Seattle for the week of August 11-16 priced at an average 30% more than than rates for the week of September 15-20.  The cost of lodging, food, and transport ensures that we will need to borrow money to cover the costs, either way. But if the expenses are combined with lost August wages, this situation is definitely a hardship not likely borne by any other party to this hearing. 
�	The Makah Tribe's counsel suggested at the pre-hearing conference that I could simply attend for “ a day or two,” as my testimony is so “short”, and that the interests of PCPW are “ well represented “ by other parties. I do take exception to those remarks, and believe that PCPW has just as much of a right and need “in common” with the Tribe to have a very active interest in the fate of Washington State's gray whales.
�	And after 20 years of attention to this issue from the perspective of the local community, and after 35 years of interest in and study of the local gray whales, I  believe that I am the best proponent of the interests of those Peninsula citizens who oppose the killing of gray whales .  Even though PCPW is without lawyers to present our case , or to review our comments ; and even though PCPW cannot retain biologists to speak at the hearing and verify our beliefs about population structures and numbers, I take strength from the fact that I speak for a great many people who have trusted me for many years to be a spokesperson for the whales . I speak also for those who I know to have been intimidated into silence on this controversial issue , on both sides of the reservation border. And although we are relieved and grateful that our cause is shared by the extremely knowledgeable and dedicated legal representation of like-minded organizations, we on the Peninsula are the ones who may once again need to live with the ground zero emotional stress and sadness of knowing that the whales we know will always be in danger of being unmercifully harassed and hunted down. It is painful enough to see the dead gray whales hitting the beaches right now, starved to death.  We experienced that before in 1999-2000.We know from experience that it will be even more heartbreaking to see them deliberately slaughtered.  I must be present for every minute of this hearing to fully represent PCPW , be able to report back in full, and to  provide information in this hearing that only a Peninsula resident can .

�	Thank you, Judge Jordan, for considering a short postponement into mid September. A great degree of stress , hardship, and conflicting commitment issues for PCPW , and other important parties, will be mitigated by this simple change.
�	                                      Thank you ,   Margaret Owens 
�	                    for the Peninsula Citizens for the Protection of Whales
�	

           

        

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