Each year since 2019, the Canadian federal government has put seasonal measures in place to reduce the threats to endangered Southern Resident killer whales. The measures are intended to create quieter waters, less vessel disturbance and less competition with fishers for the whale’s primary prey, Chinook salmon. The measures apply in the Canadian waters of the Salish Sea and Swiftsure Bank (yellow area on the map below).
Raincoast, along with our colleagues at the David Suzuki Foundation, Georgia Strait Alliance, WWF-Canada, and the Natural Resources Defense Council, have developed a guide to assist you in answering the federal government’s survey questions. You are welcome to modify these or fill out on your own.
Killer whale coalition group partners
Question 1: Do you have comments or feedback regarding the proposed salmon fishing closure (identified in blue) near the Mouth of the Fraser River?
The time and area closure for Chinook salmon at the mouth of the Fraser River is inadequate for both endangered Chinook and killer whales. The Chinook closure should begin in March to protect endangered spring stream type Chinook. The closure should also protect priority feeding areas for SRKW in August to October. As such the closed areas should be expanded south and west to capture a higher proportion of SRKW important use areas, including all of area 29-6, and expansion of areas 29-4 and 29-3.
Question 2: Do you have comments or considerations regarding the proposed salmon fishing closures (identified in blue in the map above) in the southern Gulf Islands?
There is strong evidence that SRKWs use the Gulf Islands and nearby areas in the Strait of Georgia in the winter and early spring. The start date of fishing closures should reflect this presence. Closures should be based on the first presence of SRKW after March 1. June is too late in the season to begin threat reduction measures given SRKWs can be present long before this.
Question 3: Do you have comments or considerations regarding the proposed Interim Sanctuary Zones (ISZs; identified in red in the map above) in the southern Gulf Islands?
SRKWs use the Gulf Islands and nearby areas all year, not just summer. The start date of sanctuaries should reflect this and be based on the first presence of SRKW after March 1. June is too late to begin threat reduction measures. ISZ boundaries must also be enforced; they are ignored because there are no consequences for violating them. Increased surveillance of vessels not equipped with AIS is also required. These vessels outnumber AIS-equipped vessels 8-10 to 1.
Question 4: Do you have comments or considerations regarding a proposed voluntary Speed Restricted Zone (identified in green stripes in the map above) in the southern Gulf Islands, new for 2024?
We support implementing this slowdown. However, it is critically important that the slow down area be well advertised and that it be monitored during the season to determine compliance and effectiveness. We also ask that the voluntary speed reduction zone be put in place in the early spring, starting at the same time recommended for the Interim Sanctuary Zones.
Question 5: Do you have comments or considerations regarding the proposed salmon fishing closure(s) (identified in blue in maps above) in the Juan de Fuca Strait?
Option B provides more protection for important use areas for SRKW. However, more SRKW foraging areas, especially along the shoreline near Sooke, should also be considered for fishing closures. As such, the Juan de Fuca closures in Option B should be expanded to include more areas of high use feeding.
Additional context for important feeding areas:
Question 6: Do you have comments or considerations regarding the proposed Speed Restricted Areas (Green Hatched Areas in the map above) off the west coast of Vancouver Island around Swiftsure Bank?
Speed restrictions are needed for all vessels on Swiftsure Bank. Yet, we are concerned that the 10 knot speed limit for small vessels may still be too high, and does not reflect the most recent findings of vessel disturbance that shows foraging can be disrupted within 1 km of vessels. As such, lower speeds or vessel exclusions may be required to support foraging SRKW. Increased monitoring & surveillance of non-AIS vessels and their compliance with speed restrictions is needed.
Question 7: Do you have comments or considerations regarding the proposed salmon fishing closures (identified in blue in both maps above) off the West Coast of Vancouver Island around Swiftsure Bank?
Successful feeding from spring to fall is important to the survival and recovery of Southern Residents. As such, Option 2 is the preferred scenario for SRKWs as it provides a greater opportunity for whales to feed with minimal competition from fishing, disturbance and noise from vessels in the important foraging area near the mouth of Port Renfrew.
Question 8: Do you have comments or considerations regarding the proposed approach distance and/or the impeding the path prohibition?
The 400m vessel approach distance is not in alignment with the best available science, which shows negative effects of vessel noise and disturbance on foraging within 1000m. Increasing the buffer to 1000m for all killer whales is necessary to further reduce foraging impacts and will harmonize Canadian regulations with upcoming changes in US waters.
Question 9: Do you have comments or considerations regarding the continuation of these voluntary measures?
These voluntary measures are supported, however, the extent of compliance and their effectiveness needs to be assessed. In previous years, there has been no surveillance or reporting on the extent of compliance by government. An assessment of the numbers of boaters who participate and their overall effectiveness is required.
Question 10: Do you have any comments you would like to share with the Government of Canada regarding the transition from interim management measures to long-term protections?
Yes. Effective, long term recovery measures are needed. The seasonal actions identified here need to be a broader set of comprehensive threat reduction measures on a scale biologically meaningful for SRKW survival and recovery. This includes robust measures for prey, noise and contaminants such as moving west coast Chinook interception fisheries, noise reduction targets in the Salish Sea that are meaningful for whales, and taking action to reduce contaminants in SRKW critical habitat and prey.
Further context for more comprehensive measures to recover Southern Residents
The following information won’t fit in the questionnaire, but provides an overview of what is needed for the long term.
Prey measures should address Chinook harvest not just within critical habitat, but in fisheries further north, to ensure that migrating prey reach SRKW critical habitat and other important feeding areas. Measures to address prey should focus on changes to the location and impacts of Chinook fisheries that are affecting both size and abundance of Chinook, rather than simply increasing hatchery production. Expanding critical habitat into the freshwater rivers that produce Chinook salmon should also be considered (click here to learn more about this concept).
Noise and disturbance:
Evidence suggests that vessel noise in the Salish Sea is too loud to meet the foraging needs of SRKWs. While slowdowns of large commercial ships can help to lower ship noise, the increased noise from more and bigger ships going to the TMX oil terminal in Burnaby and Terminal 2 on Roberts Bank will counter the benefits from slow downs, bringing little if any improvement to acoustic conditions for endangered whales. Regional targets for noise reductions that are ecologically meaningful and low enough to support foraging killer whales SRKW are required.
Long term and sustained efforts are required to reduce noise coming from all vessel sectors to levels that support SRKW recovery and improve the health of the Salish Sea. Additional monitoring, surveillance and enforcement of measures designed to reduce noise exposure to SRKW from small vessels is also required to limit the effects of noise and disturbance.
Despite contaminants being one of three major threats to SRKW, there are no operational measures to reduce contamination in killer whale prey or habitat. The federal government (ECCC) has initiated efforts to manage contaminants of concern to SRKW, but immediate measures that reduce them in and around SRKW critical habitat are largely absent. Enforcement of existing regulations, reviews of industrial or municipal wastewater discharges, reviews of registered agricultural pesticides, acceleration of contaminated sites assessment and remediation, and heightened scrutiny of non point source pollution (including road runoff) are largely ignored opportunities to act.
ECCC and DFO must reconcile their respective views on responsibility for water quality in support of unpolluted salmon and whales. They must also work seamlessly to protect anadromous fish from point source and non point sources of pollution. The federal government should address a continuing failure to communicate at an operational level with the Province of BC, municipal authorities and regional districts, all of which have important roles to play in stemming the release of pollutants into salmon and whale habitat.
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