DFO is about to ram yet another series of closures for fishing through. Fin Fish Closures from Long Beach, South Bank, Big Bank, Rats Nose all the way to Swiftsure. This based upon both sketchy information, and in even larger areas, no information at all.

Time to tell DFO we won't sit idly by while they take the "don't confuse me with facts" approach and adopts "assumption based science" once again.

“B.C.’s tidal water recreational fishery, combined with the freshwater fishery, is the largest and most valuable in Canada, valued at $18 billion annually. DFO issues over 350,000 tidal licences per year collecting $7.3 million in fees and the fishery employs around 8,400 British Columbian’s (as of 2012).”

· Area SRKW Refuge Recreational Fin Fish Closures will cause significant socio-economic harm destroying jobs and economic spin off activities in small coastal communities like Ucluelet, Port Alberni, Bamfield, Port Renfrew, Sooke and Victoria.

· Killer whales are only very rarely present on LaPerouse Bank, and there is no documented evidence from passive acoustic monitoring to clearly demonstrate this is actually critical habitat. DFO science is making an assumption that because areas of LaPerouse Bank are important areas for commercial and recreational Chinook fishing that they area similarly important to killer whales.

· According to Passive Acoustic Monitoring (PAM), killer whales are only present on Swiftsure Bank 43% of monitored days between May to September – broad Area Refuge closures impact recreational fishing opportunity during significant periods where the whales are not present.

· There is no comparative analysis that demonstrates the effectiveness of Area Closure vs a mobile “bubble” strategy

· More effort is required to scientifically determine if indeed there is any less benefit to be achieved using a “bubble” strategy which is less impactful – striking a balance between protection and economic activity

External review of the critical habitat section of the draft Amended Recovery Strategy for the Northern and Southern Resident Killer Whales in Canada:

http://www.pac.dfo-mpo.gc.ca/consult...index-eng.html

Deadline for feedback is July 11.

Nog