My email - with some help from AI I tried to summarize the core arguments I've seen on these threads, and support them with official DFO data where possible. Take what pieces you like for your own.
Sent to
DFO.SRKW-ERS.MPO@dfo-mpo.gc.ca, cc to my local MP, Minister of Fisheries and Oceans and Shadow Minister of Fisheries and Oceans.
Proposed 2026 SRKW Conservation Measures: Misguided and Economically Devastating
Dear Fisheries and Oceans Canada (DFO) Management and Policy Teams,
I am writing to express my profound concern regarding the proposed 2026 area-based closures for the recreational Chinook fishery in the Strait of Georgia (SOG) and Southern Vancouver Island (SVI). While I fully support science-based measures to protect and recover the Southern Resident Killer Whale (SRKW) population, these proposals appear to misdirect significant regulatory effort toward a low-impact activity, placing undue economic stress on coastal communities while neglecting far greater threats identified by DFO's own scientific findings.
My opposition is based on the following critical points, which prioritize SRKW energetic needs and actual threat abatement:
1. Disregard for Primary Threats: Acoustic Disturbance and Contaminants
DFO's own assessments consistently identify other major threats that area-based recreational fishing closures do not address and which must be the priority focus for SRKW recovery.
- SRKW Recovery Strategy Review: Identifies reduced prey availability, high contaminant loads, and acoustic/physical disturbance from vessels as the principal threats.
- Acoustic and Physical Disturbance: Vessel noise from large commercial shipping and intensive commercial whale-watching activities severely interferes with the SRKW's echolocation, making successful foraging difficult, especially for breeding females. While recent vessel strike incidents have targeted humpbacks, the chronic, pervasive acoustic impact from these high-traffic, large-vessel fleets in critical habitat poses a direct, persistent threat. Closing an area to a few recreational vessels has a negligible effect compared to the massive acoustic impacts of major vessel traffic and the constant presence of commercial viewing fleets.
2. Significant Socio-Economic Harm to Coastal Communities
Restricting the recreational Chinook fishery imposes a high cost on local communities with minimal conservation benefit, jeopardizing a crucial segment of the provincial economy.
- Economic Contribution: Recreational and sport fishing in British Columbia contributes approximately $1 billion a year to local economies in revenues and taxes.
- Employment Impact: This sector directly and indirectly supports approximately 9,000 people and their families who depend on fishing services, transportation, and accommodation for their livelihoods. Restrictive, broad closures threaten the viability of these small businesses and coastal jobs.
3. Disproportionate Focus: Negligible Recreational Harvest vs. Commercial Waste
The recreational fishery's impact on the SRKW's overall required prey base is minimal, especially when compared to the documented loss of Chinook in other sectors.
- Scientific Estimates: SRKW populations may require over 1,000,000 Chinook per year for sustenance. Stopping recreational fishing, which takes a statistically small proportion of this number, results in a negligible increase in available prey for the whales.
- Commercial Bycatch: Enhanced DFO monitoring has revealed that groundfish trawl fisheries (targeting hake and flounder) have incidentally caught and killed an estimated ~28,000 salmon (primarily Chinook) per season in recent years. This massive waste of Chinook, which includes threatened Fraser River stocks, is the equivalent of a year's food for 5 to 7 Southern Resident Killer Whales. This interception and discard of prey represents a far more significant and addressable threat to prey availability than the retention limits placed on sport fishers.
4. Foraging Realities and Non-Targeted Habitats
The efficacy of broad, area-based closures is undermined by the whales' actual foraging locations and seasonal nutritional challenges.
- Prey Availability Bottleneck: Groundbreaking hydroacoustic research (Trites & Saygili, 2024) indicates that the availability of large Chinook salmon in core SRKW summer feeding areas (Salish Sea) is higher than in the feeding areas used by the healthier Northern Resident population. This finding strongly suggests that the prey limitation bottleneck is not occurring during the summer foraging window within the proposed closure areas.
- Seasonal Malnutrition Origin: Scientific aerial body condition assessments of SRKWs often show that individuals arrive in the Salish Sea in the summer months already exhibiting poor body condition or signs of malnutrition. This, combined with the hydroacoustic findings, suggests that the critical prey limitation period is occurring during the winter and early spring months when the whales are primarily foraging along the outer coasts and south of Canadian waters (e.g., off Washington, Oregon, and California). Measures focusing solely on summer prey in the SOG fail to address this crucial, earlier nutritional deficit.
5. Alternative, Targeted, and Adaptive Management Solutions
Instead of broad, static area closures that cause economic harm with minimal ecological benefit, DFO should implement targeted and adaptive strategies that prioritize both SRKW conservation and community viability:
- Adopt Dynamic 'Moving Bubble' Sanctuaries: Instead of closing entire, large areas based on potential whale presence, DFO should leverage real-time sighting data (e.g., from the B.C. Cetacean Sighting Network) to create mandatory dynamic exclusion zones (e.g., a 1 km radius) that follow confirmed SRKW groups. This 'moving sanctuary' model ensures the whales are protected from localized acoustic and physical disturbance exactly when and where they are foraging, while allowing responsible fishing and boating outside of the immediate vicinity.
- Prioritize Marked Selective Fisheries (MSF): To meet both conservation and economic goals, DFO must shift its focus toward modern, marked selective fisheries (MSF) for Chinook. These fisheries primarily target abundant hatchery-raised Chinook (marked with an adipose clip), thereby reducing pressure on threatened wild, high-lipid Fraser River Chinook stocks that the SRKWs prefer. This approach allows local recreational fishing to continue, supporting coastal communities, while ensuring the most critical prey stocks are protected for the whales.
In Summary: I urge DFO to immediately reprioritize its conservation efforts. The proposed broad recreational closures disproportionately impact coastal livelihoods while failing to address the principal threats. DFO must focus on strengthening measures against high-impact threats:
- Strictly enforce and strengthen commercial trawl Chinook bycatch caps.
- Aggressively reduce underwater acoustic and physical disturbance from major commercial shipping traffic and high-intensity commercial whale-watching vessels.
- Implement dynamic, 'moving bubble' sanctuaries based on real-time SRKW sightings.
- Immediately transition recreational fisheries to Marked Selective Fisheries (MSF) to prioritize the protection and increase of the large, wild Chinook stocks preferred by SRKWs.
- Invest in contaminant reduction and habitat-based rebuilding of high-quality Fraser River Chinook stocks.
Thank you for considering this science- and economics-informed feedback.
Sincerely,
REDACTED
