Offering up the input sent to DFO from WCFGA - will break this into a few segments so it fits into the forum format. We know there are others who are preparing to draft and send your input, so if you find any of these points useful in drafting your response, that is why we are posting to this site.
PART 1:
West Coast Fishing Guides Association
March 12, 2018
We are reaching out to the Department to offer our advice with respect to developing a solid SRKW Action Plan and Management Measures for 2018, and beyond.
Of foremost concern is whatever plan we eventually land upon must achieve the desired outcomes to benefit whale recovery. Our desire is to offer viable management alternatives that serve to improve SRKW acquisition of prey by reducing both physical and acoustic disturbances. Our Association strongly supports taking meaningful actions that provide science-based solutions that achieve actual reductions in disturbances impacting SRKW recovery.
Additionally, our Association believes that significant investments are required to increase Chinook abundance, which in turn creates improved prey availability for SRKW’s.
SRKW Action Plan
Action Plan objectives – increase Chinook abundance as prey; reduce feeding interruptions to enhance SRKW prey acquisition success.
Strategies
1. Education and Awareness:
Avoidance is a critical strategy to ensure the feeding activity of whales is not disrupted. Prey disturbance from vessels jumping in front of whales as they pursue their prey is an observed contributor to SRKW not successfully acquiring prey. Accordingly, we believe a significant public awareness campaign is necessary to inform vessel operators of the importance of avoidance. This also includes providing public education brochures to recreational boaters and guests on whale watching excursions to explain why the vessel master is maintaining a safe distance.
To be successful this strategy will rely upon vessel operators avoiding disrupting the prey and feeding activity of SRKW’s. Public awareness and acceptance of the rationale behind avoiding close contact is imperative to changing vessel operator habits on the water.
2. 400 m Spatial Vessel Exclusion (Bubble) Zone:
The Departmental regulations amendment had a buffer distance of 100 m from the whales, which has now been increased to 200 m. This is a good step forward, but we believe it is
not enough. The Whale Watching Guidelines allows boaters to stay near the whales with the engine running, and travel in a parallel direction with the whales. For example:
“If whales are approaching you, cautiously move out of the way. DO NOT APPROACH whales from the front or from behind. Always approach and depart whales from the side, moving in a direction parallel to the direction of the whales. DO NOT APPROACH or position your vessel closer than 200 meters/yards to any whale.”
We are proposing a regulation requiring
all vessel operators to maintain a 400-meter spatial exclusion. We recommend 400m is the size required to ensure we achieve physical and acoustic protection to enhance feeding success of killer whales. Research indicates where vessel operators are in close proximity with whales, feeding behaviors are disrupted. This results in 18 – 25% decrease in observed feeding, and 17% increase in expended energy for whales to acquire prey.
Where vessel operators find themselves in closer proximity, the suggested regulation would require:
· Vessels engaged in fishing activity, immediately stop and pull gear out of the water
· Vessel operators
slowly leave the exclusion area
· Turn off all depth sounding equipment to reduce acoustic disruptions
· Slow departure is important in reducing acoustic disturbance
Moreover, we have observed vessel operators who practice leapfrogging ahead of the projected direction of whale travel in order to get a closer viewpoint when the whales eventually arrive. This activity is commonplace, and in our experience disrupts the baitfish that Chinook salmon prey upon. In turn, Chinook disburse making it more difficult for SRKW’s to acquire prey. We recommend specific regulations to end the leapfrogging practice. The US NOAA regulations recognize this activity:
“Federal Regulations for killer whales require that boaters stay 200 yards away & keep path of the whales clear. These U.S. regulations apply to all vessels.”
We recognize that SRKW are highly mobile. Area closures to vessel traffic or refuge zones only protect whales in situations where they are actually present in the environment. A spatial exclusion zone (or bubble) of 400 m provides improved buffers, offering a mobile protection area, which allows undisturbed feeding and more effective prey acquisition. This strategy takes aim at vessel interactions that impact SRKW prey acquisition, which represents a more impactful way to improve feeding than harvest reduction.
We recognize spatial exclusion zones do create hardship for vessel operators wishing to recreationally fish these areas, and also for whale watching tour operators. Notwithstanding, we believe this strategy achieves the right balance between providing acoustic protection, effective prey acquisition, and meeting needs of vessel operators.
Our strong preference is to use a more surgical approach by employing a mobile spatial vessel exclusion strategy as this affords protection while balancing access for vessel operations.