Scientific literature estimates that the actual ratio between unobserved offshore mortalities and observed onshore mortalities ranges from 7-to-1 to 25-to-1.
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Ecologists note that stranded cetaceans are emaciated, and a scientific consensus indicates they are starving due to loss of food access driven by dramatic sea ice reduction around Alaska.
"The environment may now be changing at a pace or in ways that is testing the time-honored ability of the population to rapidly rebound while it adjusts to a new ecological regime," said David Weller, a NOAA marine biologist.
Beyond climate factors, some stranded whales show signs of ship strikes, and Indigenous populations in Russia hunt the species, killing up to 40 whales annually.
Advocacy groups also claim the Trump administration is actively increasing regional oil drilling, introducing more pollution and environmental threats.
A formal NOAA response to the federal petition is due in about a month.
"The gray whales are in dire straits, so hopefully they see that and this can be the first one they list," Steiner said.
If the administration rejects the request, PEER plans to file a lawsuit, noting that the second Trump administration has not yet added any animal to the protected list.
California currently maintains voluntary ship speed reduction zones that have successfully halved whale ship strike deaths in those specific waters.
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"If you lose thousands of whales in two years – that should concern everyone," Steiner said.
